SUBMISSION BY
THE AUSTRALIAN BANKERS' ASSOCIATION
TO
THE HUMAN RIGHTS AND EQUAL OPPORTUNITY COMMISSION
Background
The Australian financial services sector is diverse and dynamic. For instance, there are now 25 banks, 19 building societies and about 320 credit unions providing retail banking services to more than 17 million Australian consumers. Each year customers carry out more than three thousand million transactions (not counting inquiries, interviews and other non-financial activities).
More than 80 per cent of transactions are done electronically - mostly through self-service technology such as Automatic Tellers Machines (ATMs), Electronic Funds Transfer at Point of Sale (EFTPOS), telephone banking, and on-line internet banking. Each month Australians make 43 million ATM withdrawals, 42.7 million credit card transactions and 49.7 million EFTPOS transactions.
Banks, building societies and credit unions have invested many millions of dollars since 1980 to build a national network of 9,387 ATMs and 265,391 EFTPOS terminals. They continue to invest in equipment replacement and upgrade programs as well as the newer services, telephone and Internet banking. Already, more than five million Australians are telephone banking (some banks report a doubling of telephone customers in the past year) and thousands have signed up for on-line services.
It is all part of the changing face of banking. Twenty years ago banking could be done only through a branch or a post office agency or with a cheque book. Branches were open from 10am to 3pm Monday to Thursday and until 4pm on Friday. Today, customers need only a coded plastic card, access to a telephone and a personal identification number to operate their bank accounts 24 hours a day, seven days a week, 365 days a year from anywhere in the world.
The change has been driven by three factors - customer demand, competition in a de-regulated market and the related drive for efficiency in operations. Concurrently, rapid developments in computer technology have made self-service banking possible on a widely accessible scale. It is now possible to access a bank account from any EFTPOS terminal and almost any ATM (although there is a fee to cover the interface cost of the ATM networks).
However, throughout the technological revolution of the past 20 years, traditional, over-the-counter banking service has been retained. There are still almost 12 thousand bank branches and agencies, and the number is increasing with the advent of supermarket banking, pharmacy banking, in-store branches and franchised operations. Most banks see a role for over-the-counter service well into the foreseeable future.
Choice
Developments in self-service banking offer greater choice for customers. In most cases EFTPOS, ATMs, telephone banking and Internet banking are effective alternatives to the counter. There is little or no banking that can't be done through one of these four forms of self-service banking - cash withdrawal, deposits, account balances, transaction reports, funds transfer between accounts, bill paying, ordering of deposit books and cheque books, loan applications and purchases.
The decision, as in all financial matters, will be determined by the customer, largely on the basis of personal taste, financial values and lifestyle.
In a highly competitive market, banks, building societies and credit unions look to tailored products to win markets. At times they offer similar products and services, but often they try to distinguish themselves from competitors. Consumers can shop around to find the best products and the best deals to suit their circumstances. Part of the choice will be cost.
Cost
Australia has one of the best prudential regulatory systems in the world. This has contributed to a safe, secure and stable financial system. One of the most significant decisions of regulators during the past decade was to encourage the move to a user-pays regime in banking. After decades of cross subsidisation, banks no longer impose hidden levies on borrowers to recover the cost of other customers' banking. Consumers of banking services now pay only for what they use. For most, this has meant significant savings. But, for others, it has meant paying for banking for the first time in their lives.
Some have misunderstood this transition to user-pays, thinking that the account keeping charges and transaction fees result from profiteering or from technological changes. On the contrary, technology has delivered efficiency and economy to those who use it. Banking is not only more accessible than ever before, it is also be cheaper for those who choose to serve themselves.
For customers who prefer traditional banking methods including passbooks and counter service, the service will still be available. However, the price will reflect the cost of providing the service.
Although not commonly acknowledged, fees on personal transaction accounts contribute less than 2.7 per cent of bank revenue. And, in many cases, fees are still not recovering the full cost of providing services.
Up to half bank customers pay no monthly fees on their accounts or transaction fees. The remainder pay, on average, less than nine dollars a month for full service banking. Most banks offers special accounts for students, seniors, pensioners and low income earners. These accounts have little or no monthly fee and a number of fee-free transactions each month. Also, most banks have special arrangements for disabled customers who are unable to use self-service banking. The criteria vary from bank to bank.
The concerned
Not all Australians believe they have benefited from the improvements in banking technology. This includes some older people and some people with disabilities.
Of course most of these people are confronted by new technology in many aspects of their lives (e.g. push button telephones, self-service petrol bowsers, public transport ticketing machines, telephone inquiry and bill paying services, remote control televisions). However, banking seems to have attracted the bulk of media attention.
Most older people and the disabled are quite capable of learning about, and benefiting from, one or more of the self-service banking technologies.
In fact, ABS statistics and banking industry experience shows that about a third of older people and many disabled people are already using self-service banking technologies on a regular basis.
However, a minority face seemingly insurmountable barriers - either physical or psychological.
Older customers
Australia decided in the International Year of the Older Person, that an older person was someone over 50 years of age. Based on Australian Bureau of Statistics (ABS) population profiles, that means that more than five million customers of banks, building societies and credit unions fall into the category of "older" customers.
Some people over 50 are also disabled (physically or intellectually) to some degree.
People over 50 formed their adult values in an era when an attendant filled the car petrol tank while also washing the windscreen and checking the oil and tyre pressure. Shops closed at lunch time on Saturday and re-opened on Monday morning. It was also the era of 10 to 3 banking at the branch.
Banking mirrors the changes in society generally during the past 20 years. Self-service is usually the cheap alternative whether it's fast food, fuel or movies. But, some people are prepared to pay a little extra to stick with the traditional product.
This social change to emphasis on speed, convenience and lower cost has not appealed to everyone - especially some senior members of the community who resist on principal.
For others, the pace and magnitude of change generally has simply been overwhelming. Either because of illness, disability, age or an aversion to computers and technology, they have failed to keep up. They have no desire to catch up and would rather be left with the ways they know.
But there is a large group of older Australians who want to know about the new technologies, especially in banking. However, they lack the necessary information and support and they have concerns about safety and security.
The banking industry has been aware for some time of the three segments of older Australia. Individually and collectively, banks have tried to cater for all three.
By maintaining (and now expanding) the network of over-the-counter facilities, banks have provided older customers who choose not to use self-service technology with a traditional alternative. Although over-the-counter service is far and way the most expensive form of banking to deliver, most banks have acknowledged the concerns of some older customers by providing special accounts with little or no monthly account keeping fee and a package of fee-free transactions. Terms and conditions vary between banks,
For those older customers wanting to learn about the new technologies, most banks have provided information material, and a number have also conducted information seminar programs. One bank has been conducting more than a thousand seminars a year for community and welfare groups.
In July, 1998, the Australian Bankers' Association entered into a partnership with eight leading community organisations representing the interests of older Australians to establish a national program on self-service banking. With the support of the Prime Minister's Business/Community Partnerships program and under the banner of the International Year of the Older Person, a program called Self-service Banking and Older Australians was launched in all States and Territories.
The program is based on information and experience, allowing older people to hear about self-service banking, to ask questions of bank experts, and then to try their hand at demonstration equipment.
Seven banks have participated in the program. The industry has funded market research, the design and production of generic video and brochure material, and all bank participation costs including travel, staff and equipment.
While crime statistics show that there is a far greater risk of attack against older people in the street and in even in their home than at an ATM, that is not the perception of many in the community. As part of the general program of community education, banks explain ways to protect personal safety and to avoid risk in handling money and banking. There are risk assessments carried out on ATM sites regularly to take account of changing conditions and activity.
Disabled
The ABS estimates that about two million Australians under the age of 50 are disabled to some degree (either physically or intellectually). Most of these would be bank, credit union or building society customers.
Many of these people have encountered problems in daily life for many years, including with traditional banking. For example: those with intellectual disabilities or cognitive difficulties may have had difficulties with signatures, figures and documents; those with serious mobility limitations may have had difficulty accessing branches and agencies; and sight impaired customers may have had difficulty with formal documents, forms, brochures and passbooks.
The banking industry has devoted significant effort and expense over many years to recognise the difficulties encountered by disabled people. Bank building and equipment design and siting has been improved to ensure that all appropriate Australian design standards are met, some banks have introduced telephone typewriter services for the hearing impaired, and most banks have adopted a discretionary policy of allowing disabled customers who cannot use ATMs to use counter services without additional cost.
The industry is committed to the principals expressed in the Commonwealth Disability Discrimination Act. Many banks have even adopted their own disability action plans for staff and customers alike. However, it is apparent that there is not always agreement, even among the experts, on the most appropriate solutions or strategies for addressing specific access issues for the disabled.
The ongoing evaluation and improvement of ATM design (including screens) takes account of Australian Design Standards as well as advice from individuals and groups representing the disabled. It was community advice that resulted in some ATM keyboards being equipped with Braille buttons more than 10 years ago (even though Braille is used by only a small number of Australians and is not usually the choice of older people). New generation equipment incorporating audio, touch-screen and other aids are now appearing (although the considerable cost associated with large network technology may influence the speed and extent of upgrades).
But, most importantly, self-service banking technology has provided disabled customers with new, or more convenient access, to banking. Those with limited mobility can bank from home by telephone, paying bills, checking account balances, transferring funds between accounts, and monitoring transaction histories. They can also apply for loans, order banking stationery and monitor interest rates and other funds management information over the phone. By using EFTPOS they can now shop and withdraw cash from their account at the same time, reducing the need to visit a bank in addition to their other activities. Because of the interfaced network of ATMs, they can withdraw cash, transfer funds between accounts, check account balances, print a transaction history, and in some cases make deposits, at almost any bank's machine.
Sight impaired Australians are now able to live with greater independence and privacy thanks to technology. Bank customers with sight limitations have a range of services available conveniently through telephone banking. In conjunction with telephone providers and manufacturers, special handsets are available at reasonable cost to allow for the most efficient use of telephone banking.
People with hearing impairment have the choice of ATM, EFTPOS and Internet banking without limitation.
Those with cognitive difficulties, who might otherwise make use of the technology if not for difficulty with, say, Personal Identification Numbers (PINs) now have the choice of words as well as numbers. And, we are on the verge of a new era in identification with Iris, fingerprint and other recognition technology being introduced and trialled worldwide.
In its simplest form, the industry expression of commitment to the disabled can be seen in the design of EFTPOS keyboards that assist those with arthritis and other debilitating limb diseases.
In reality, few service industries have demonstrated a greater consideration for the disabled than banking.
Outside our control
Despite the best efforts of banks to deal with issues confronting older customers and those with disabilities, there are some influencing factors outside the industry's control. For instance, telecommunications infrastructure shortcomings have prevented some people in remote areas from using telephone and internet banking.
This has also limited the effectiveness of EFTPOS and ATM services in these areas. However, banks have co-operated in trials using satellite telephone to overcome the limitations.
Also, heritage laws and local government planning priorities have sometimes conflicted with safety and access considerations in the siting of ATMs and building access (including ramps). However, banks have worked to find solutions - sometimes at considerable expense.
In summary
The financial services sector is aware of the issues and concerns of some older Australians and some disabled in relation to technology and self-service banking. It is acting to address them.
The industry is committed to the principals expressed in legislation and codes requiring equality of access. Appropriate national design standards are applied in relation to buildings and equipment.
Individually banks respond as best they can to customer demands and needs. Some express the response to disabled through company action plans. Individually and collectively, bank support for older customers can be seen in national programs such as Self-service Banking and Older Australians.
The banking industry believes that new technology, particularly self-service banking technology, provides all customers with greater choice for flexibility in banking and lower cost. It recognises that not all people will choose to take to the alternative forms of banking, even though that decision may cost them money.
Banking services are charged on a user-pays basis. Fees are not structured to discourage or penalise those not using self-service banking - they simply reflect the actual cost of delivering each form of service. Special consideration is given by most banks to customers who are unable to use the cheaper forms of banking because of disability or incapacity, including through relief from fees.
The industry is committed to retaining choice in service - including the choice of over-the-counter service - and will continue to develop opportunities for further improvements.
11 NOVEMBER, 1999