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COBA includes vulnerability obligations to its code

Customer-owned banking institutions will need to apply more stringent measures to ensure vulnerable customers are identified and supported. 

As part of an update to the Customer Owned Banking Code of Practice (the Code), the Customer Owned Banking Association (COBA) has included specific obligations for the treatment of different types of vulnerability that may be experienced by customers.

The 2022 Code, which comes into effect on 31 October 2022, includes 10 new obligations relating to the identification and treatment of customers experiencing vulnerability.

Among the changes include taking “reasonable steps” to make banking services accessible for individual customers who speak English as a second language, older customers, people with a disability, and First Nations Peoples.

The Code also sets out obligations around training of staff to identify customers experiencing vulnerability.

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It comes following a report, by the independent committee that monitors the Code, which called for a “sharper focus” on customers experiencing elder abuse or family violence in particular.

The study found while about two-thirds of subscribers reported having policies and processes in place that address vulnerability relating to elder abuse (63 per cent), only one in five subscribers had a dedicated team or staff member.

As such, the report suggests widening the ways of detecting customers who may be experiencing vulnerability, rather than relying solely on staff to recognise red flags or customers to identify themselves as needing help.

The report also noted, while consumer vulnerability was placed firmly in the spotlight by royal commissions, the COVID pandemic and more frequent and severe natural disasters had increased the number of people experiencing vulnerability.

The chair of the committee Jocelyn Furlan said vulnerability can happen at any time and was a challenge for Australian businesses.

“It presents a significant challenge to all Australian businesses, including customer-owned banking institutions, whose very purpose is to improve the financial wellbeing of their customers and communities,” Ms Furlan said.

The report recommends that all subscribers (there were 56 as at 30 April 2022) review their vulnerability frameworks ahead of the introduction of the new Code in October.

[Related: ABA consults on dealing with vulnerable customers]

COBA includes vulnerability obligations to its code
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