For bank and building society staff
If you work at a bank or building society, you may feel unsure how to support a customer who has experienced economic abuse.
This information may help you to create an environment in which the customer feels able to share information with you. It may also help you feel prepared to respond to the customer.
We recommend reading our other resources for bank and building society staff:
On this page
Familiarise yourself with the guidance on responding to vulnerable customers
The Financial Conduct Authority’s guidance on the fair treatment of vulnerable customers and the UK Finance 2021 Financial Abuse Code set out the ways in which banks and building societies should respond to customers in vulnerable circumstances, which includes domestic abuse and economic control. We recommend that you familiarise yourself with this guidance, which the following information is based on.
The new Consumer Duty also sets higher standards of consumer protection across financial services. The Duty induces a consumer principle (Principle 12) to the FCA’s overarching rules and requires firms to put their consumers’ needs first. There is a particular emphasis on treatment of consumers with characteristics of vulnerability or who may be at a greater risk of harm. The Consumer Duty provides financial services firms with an opportunity to transform their response to economic abuse.
Current responses to economic abuse predominantly focus on addressing negative outcomes for victim-survivors after things have already gone wrong. However, these outcomes could be prevented from happening and the impact on survivors minimised if an understanding of economic abuse was reflected within end-to-end product and service design.
The Consumer Duty builds on the FCA’s existing guidance on fair treatment of vulnerable customers and, through Principle 12, imposes a higher standard on firms in several ways:
- The Duty introduces rules and a Principle for Business into the FCA Handbook (and guidance) that consistently and explicitly requires firms to consider consumers with characteristics of vulnerability
- The FCA is clear that the Consumer Duty raises the standard of care afforded to all consumers and requires firms to consider where products and services may cause foreseeable harms to consumers and seek to reduce these
We have developed a briefing paper in partnership with the law firm Simmons & Simmons to help financial services firms consider economic abuse when interpreting what good outcomes (Principle 12) look like for victim-survivors.
Examples from the briefing on how firms can help victim-survivors of economic abuse:
- Considering how accessible it is to obtain credit online with no human interaction and setting up extra security questions and safe words when there are known issues of domestic abuse.
- Considering ways to reduce perpetrators’ opportunities to exploit products like credit cards and loans. This might be through reviewing the account terms and conditions, restricting the option to add named card holders to credit cards and/ or applying positive friction when lending.
- Ensuring that there are specialist teams in place who can provide support to victim survivors and help them gain financial independence from the perpetrator.
- Ensuring staff have received the relevant training to identify economic abuse and respond adequately to disclosure – again eliminating any further harm.
- Ensuring that the financial business isn’t gaining financially as a result of economic abuse – for example, considering putting a freeze on interest or writing it off and removing fees and charges.
For further guidance on the Consumer Duty, download ‘How the Consumer Duty can transform responses to economic abuse’
The guidance that exists on supporting vulnerable customers builds on the skills you already have to empathise and build rapport with customers. The information below may help you apply these skills to the needs of victim-survivors of economic abuse.
Understand why a customer may not disclose abuse
Some customers may be forthcoming with information about the abuse they are experiencing and may raise the topic with you. However, there are a number of reasons why other customers may not disclose that economic abuse is taking place. They may:
- find it very difficult to talk about economic abuse
- be afraid of the response they might receive
- be unaware that the bank is able to support them
- be afraid of the abuser finding out – the abuser may have threatened them so they don’t share information
- be coming to terms with the abuse they are experiencing
- not be fully aware that what they are experiencing is abuse.
They may not even be aware of the full extent of the abuse if the abuser has hidden information from them.
The information below includes ways in which you can make it easier for a customer to talk to you about what has happened, whether or not they have named their experience as ‘economic abuse’.
Establish trust
A customer may be unsure of the response they will receive from the bank if they disclose the abuse they have experienced. It may help to reassure the customer that they won’t be penalised or blacklisted for seeking your support.
You could invite the customer to speak to the bank’s vulnerable customer team, if there is one. This is a specialist team that is trained in offering support to customers in difficult circumstances, including those experiencing abuse. It can help to explain what the vulnerable customer team can do to support them. Some banks can support customers to freeze or close accounts, or open a new bank account safely. Explaining the ways in which the bank can support the customer, and what their next steps may be, can make it easier for them to talk to you.
It may also help to reassure the customer that the information they share with you will be confidential.
Discussion prompts:
- I understand it may be daunting to share information with us, but the bank is here to support you with financial matters.
- Your safety and wellbeing is our top priority.
- Everything you tell the bank will be kept confidential.
- There are a number of ways in which the bank may be able to support you to regain control of your finances.
- What can we do to help you feel safe/protected?
- If relevant – We have a customer support team that is trained in supporting vulnerable customers. Would you like to speak to them?
Make sure the time and place is right for the conversation
Before a customer tells you about the abuse they have experienced, make sure it is the right time and place for the conversation. Try to create a safe environment that makes it easier for a customer to talk to you about what is happening.
- Check how the customer would prefer to speak to you – would they prefer a phone call, a video call, or would they like to make an appointment to speak to you face-to-face at the bank branch?
- Make sure that the conversation with the customer can’t be overheard, whether in person, over the phone or on a video call.
- If you are speaking on the phone, remember that the customer will need to speak to you when their partner is not around. It can help to establish a codeword that the customer can use to signal that they are unable to continue with the conversation, for example because their partner has returned home. Remember to ask if there is a convenient time that you could call back if the conversation is interrupted.
- Would the customer like you to pretend to be someone else if the phone was to be suddenly taken by the abuser?
Discussion prompts:
- Is this a convenient time for you to talk?
- Do you have enough time now or would another time suit you better?
- Would it help if we set a code word you can use if you need to end the call suddenly?
- If the phone is taken by another person, would you like me to pretend to be someone else?
- Is there anything else I can do to help ensure your safety during this call?
Listen
Applying your active listening skills is important to create an environment in which a customer can speak openly. It will also help to ensure that you learn as much information as possible to allow you to support them in the appropriate ways.
Remember to give space and time for the customer to explain the situation.
Discussion prompts:
- Thank you for sharing this information with me today. Would you like to continue telling me about what has happened?
- Knowing the detail about what you have experienced will help me to support you better, so please share as much information as you feel able to.
Minimise the need for the customer to repeat their story
It can be difficult for people experiencing economic abuse to share their story, let alone share them more than once. With the customer’s consent, note their story securely on their file to minimise the need for them to repeat it to other staff members or departments.
Prioritise the customer’s safety
Don’t pressurise the customer into taking any actions:
The customer is the best judge of whether taking any actions to change their financial situation may lead to further harm from the abuser.
Keep the information the customer shares with you confidential:
The customer may be concerned that the information they share with you will be accessible to the abuser if they have a joint account or a joint product. Ensure that sensitive items are flagged on the customer’s profile. This will inform any colleagues who speak to the customer or the abuser in relation to joint products of the circumstances.
Speaking to the customer’s family or friends:
The customer may ask you to speak to a friend or relative on their behalf. It is important to be aware that sometimes customers may experience abuse by family members. If the customer has a family member or friend with them in person or on the phone, try to make sure that they are able to speak freely in front of this person. If you have any concerns, it is best to speak directly to the customer or suggest that you speak to them at a time when they are alone.
Alert the police if necessary:
If you have reason to believe that a customer may be in immediate danger, you may consider alerting the police. Be aware that alerting the police may in some cases put the customer at further risk, and this is only appropriate in extreme circumstances. Speak to the customer about whether they would like you to involve the police and ensure that they are aware of your intention to do so before you call.
Updated July 2023
