Submission to the Australian Banking Association

The Australian Banking Association has asked for submissions on new industry guidelines regarding vulnerability. The new guideline will outline ABA members’ commitment to ensuring customers can access appropriate banking products and services, which are suitable and fair for their circumstance.

WIRE provided a submission building on our work from the Women and Money Project and Dr Nilmini Fernando’s research,  “When is the right time talk about money? Financial Teachable moments for women affected by family violence”.  Our submission focused on the diversity of women who require the services of hardships teams and extra support when accessing banking institutions.

In our submission we call for:

• an intersectional framework to be factored into and explicitly mentioned as part of the definition and description of vulnerability
• vulnerability to incorporate an understanding the victim-survivors of family violence are both vulnerable and resilient and require agency in decision making
• vulnerability to incorporate an understanding of the lack of bandwidth people under stress have to take in information and banks need to factors this in to their response
• the safety of customers who are family violence victim-survivors to be paramount and fully considered before the sharing of any information with any third party takes place
• new products and procedures to be developed using human-centred design and incorporate the views and wisdom of people who are experts by experience