Submission:

Commonwealth Bank of Australia

• Executive Summary pg 3
• Trend to electronic banking pg 4
• Channels/Products pg 5

• Information and Education pg 9
• Sponsorship and Concessions pg 12
• Accessibility pg 13
• Conclusion pg 16

The Commonwealth Bank's submission in response to the Government's inquiry (into accessibility of electronic commerce and other new service delivery technologies for older Australians and people with a disability), highlights initiatives which ensure the benefits of newer technologies are available to all Bank customers.

The Bank is continuing its longstanding commitment to serve all Australians, by ensuring flexibility and choice in providing a wide range of financial products and services.

The Commonwealth Bank has 7.7 million customers Australia-wide and is Australia's most accessible Bank with well over 100,000 points of contact.

Currently, four out of every five transactions by Commonwealth Bank customers are conducted electronically. This use of electronic services has been growing rapidly, a trend that is expected to continue. Electronic transactions may be made using Automatic Teller Machines, Electronic Funds Transfer Point of Service (EFTPOS), telephone banking or the Internet. The Bank continues to operate Australia's largest network of face to face contact points with an extensive national network of over 5,000 branches and agencies.

Technological innovations can enhance the ability of older customers and customers with a disability to use financial services. Electronic banking generally offers customers greater flexibility, convenience and efficiency. To assist customers familiarise themselves with these newer technologies, the Bank has a long-standing information and education program in place.

Where customers are not able to take advantage of electronic banking, the Bank has acted to ensure that groups such as the elderly and customers with a disability, receive special assistance by way of additional services and fee-free banking.

The trend towards electronic banking as distinct from traditional branch banking, has been increasing at a rapid rate. For example in 1994 over 50% of all Commonwealth Bank transactions were conducted over the branch counter; in 1999 this figure is just 20% (see attach.1).

The Bank has invested heavily in new technologies to allow customers more time efficient and less costly ways of conducting their banking.

As expected the take-up rate of technology, across different sections of the Bank's customer base, has been varied.

The Commonwealth Bank has a greater proportion of older customers than any other financial institution in Australia. In view of this, the following information in relation to electronic banking may be of particular interest.

• Almost 75% of pensioner deeming accounts opened currently are card-based (electronic) - with only 25% opting for the Passbook option.
• In the past month alone, a quarter of a million Bank customers over age 65 used electronic banking facilities.
• Over the past twelve months, usage of EFTPOS amongst customers over the age of 65 years has grown by more than 50%.

The development of alternate service delivery channels offers customers a far wider choice for their banking and financial arrangements.

Channels such as EFTPOS, telephone banking and Internet banking allow customers, particularly older customers and customers with a disability, to conduct their transactions with greater ease, more privacy, less reliance on mobility and within the confines of their own home or local retail outlet.

Where opportunities exist, the Bank has modified use of these channels to further enhance access for older customers and those with a disability.

EFTPOS is the Bank's fastest growing delivery channel. Commonwealth Bank customers conduct around 200 million financial transactions using EFTPOS each year, with an annual growth rate approaching 20 per cent.

An initiative launched in alliance with Woolworths this year, Ezy Banking, offers particular benefit to older customers who may prefer to conduct more frequent, lower value transactions.

An Ezy Bank account can be used in any one of 640 Woolworths stores around Australia as well as other access points. Full rollout will be complete by June 2000. This account offers:

• 50 free electronic withdrawals from Woolworths Supermarkets and Big W stores per month
• an additional 5 free electronic withdrawals per month from outside Woolworths stores (that is, any Commonwealth Bank ATM, Internet and EFTPOS)
• no account keeping fees or minimum monthly balance requirement
• enrolment in a comprehensive reward programme including partners such as Qantas and Village Cinemas.
• an all in one card offering both an Ezy Action Account (transaction account) and an Ezy MasterCard (a credit account)
• highly competitive interest rates on both accounts
• Call centre available for account set up, support, help etc (24hrs a day, 7 days a week).
• Phone banking access in store
• Access to check account balance in store

Internet banking (NetBank)

Older customers and customers with a disability who have access to the Internet can also bank from home using NetBank, the Bank's Internet banking service. NetBank has the added advantage of being accessible 24 hours a day, 7 days per week, from anywhere in the world.

NetBank is a program obtained from the Bank's Web site, which allows our customers to do basic banking transactions securely over the Internet. It will be replaced early in calendar 2000 with a browser-based banking solution. This uses the same software that customers use to view any other Web site. As a browser-based solution, it will also be able to be used on Macintosh operating systems, as well as Windows operating systems.

Over 5% of current NetBank users are aged over 55, a figure that is expected to increase over time.

In developing the Web site, attention has been made to introduce features to assist the visually impaired such as use of an Alt Tag. An Alt Tag is the description that is attached to a graphic or file which appears where the graphic loads. Software such as disability readers use the Alt Tag to interpret to a user (such as a visually impaired person) what the file is.

The Bank's online stockbroker, Commonwealth Securities, has noted positive feedback from customers with a disability (mainly vision impaired) concerning use of Alt Tags.

The Bank will continue to monitor new user software that becomes available, and will consult peak organisations for people with a disability to utilise functionality of the available software.

Automatic Teller Machines (ATMs)

Commonwealth Bank ATMs have been modified to assist those customers who have sight or mobility impairments.

Of the Bank's 2660 ATMs, 960 already have Braille keypads. More than 71% of those ATMs which are able to take a Braille keypad have had one installed. It is the Bank's policy that all new ATM installations include a Braille keypad.

Variable ATM heights and screen/keyboard positions exist in most locations with multiple ATMs and wheel chair access. All new ATMs that are installed meet the height and user requirements specified by Australian standards. They also have larger and clearer display screens than older models.

Branch staff have been especially trained to assist customers become more comfortable with using ATMs. Customers need simply arrange a demonstration with their branch staff to receive assistance.

To use the telephone banking facilities, a customer only needs a touch tone phone. Customers can access the Bank's telephone banking facilities by calling 132221.

Advantages of banking via the telephone for all customers include saved time and increased convenience. Telephone banking overcomes travel difficulties and introduces flexibility in hours to clients with limited mobility.

Customers can either speak to telephone staff or use the automated service. The automated service provides evening and weekend access - 7:00am - 11:00pm 365 days a year. This service is also accessible from overseas.

The Bank is aware of research that suggests that many older users of telephone banking often prefer to speak to a person, although this trend is changing. During a telephone banking transaction, customers need simply press "0#" (they are reminded of this during their call) to be put through to telephone staff. Staff are available on telephone banking from 8:00am to 8:00pm Monday to Friday. If during a telephone banking transaction an incorrect prompt or PIN is entered, the customer is transferred to an operator who can assist in completion of the transaction.

Brochures on "Telephone Banking" and "Banking Made Easy" have been produced and older clients are increasingly adopting electronic banking. 10% of all 13 2221 users are aged over 55.

The Telephone Typewriter (TTY) Service enables those clients who are hearing or speech impaired - but want to bank via the telephone, to perform all functions available through the regular telephone banking service.

Access to TTY is a freecall to 1800 240 889, and is available from Monday to Friday 8:00am to 8:00pm.

TTY customers can obtain the same information as clients who use the Bank's automated service. Both services allow customers to check account balances; transfer funds, pay their Commonwealth Bank credit card and other bills (via BPAY) and check foreign currency rates.

The Bank is a participant in the BPAY scheme which allows customers to pay many of their regular bills using Telephone Banking or NetBank. BPAY is a convenient service which removes the need for customers to leave their home, and carry cash, to pay their bills.

Direct Debits can be set up to automatically pay regular bills.

The Bank understands that some older customers and those with a disability may have difficulty either carrying out their banking on their own or accessing information about their accounts. To assist customers faced with such problems the Bank provides:

• Multiple account access so that a relative or trusted friend may act on behalf of an older or disabled person.
• Separate Identification and Personal Identification Numbers (PINs) issued to use through all channels
• Opportunity to select preferred PIN, which is more easily remembered.
• Braille statements issued for visually impaired (on request). These are free of charge to the customer.

The Bank has a number of programs in place to assist older customers and customers with a disability to find out more about alternative methods of banking.

The Bank actively promotes seminars and presentations to interested groups in the community to provide information and training on the advantages of electronic banking.

This process formally commenced in 1996 when the Bank launched its Older Persons' Education Program. Since the program's inception, over 1,000 older persons groups have taken up the Bank's standing offer to run seminars on self-service banking.

This year, the Bank has enlisted the assistance of retired Bank officers, to deliver the seminars, as they have a peer group affinity with the audience. The presentations include the screening and discussion of videos specially produced by the Bank, as a way of explaining to our older customers the benefits of electronic banking (copies of the Bank's videos are enclosed).

The seminars also feature a discussion about the different methods by which older people can conduct their banking. Participants have the opportunity to gain hands on experience in using EFTPOS and ATMs with demonstration equipment, specially designed for use in these seminars.

In March this year the Bank reiterated its longstanding open offer to conduct seminars on alternative means of banking by writing to over 4,000 older person's groups around Australia. The results to date are very encouraging with over 400 seminars conducted this year alone, and a further 100 requests in the pipeline.

These seminars held over the past three years have also been used as an effective feedback process for the Bank. Older customers have been able to directly convey any concerns they may have about adopting alternative means of banking, and the Bank in turn has been able to fine tune some of its practices to address these concerns.

A notable example is the brochure designed specifically for older customers entitled "self-service banking". Feedback from older person's groups was that some older customers with sight impairment found the Bank's brochures difficult to read because of the glossy paper and size of font. In response, the Bank produced, and now uses an A4 (rather than A5) paper size, large print, non-reflective paper, specifically designed for older or sight impaired customers (a copy is attached).

The Bank produces Audio Taped Newsletters for visually impaired (Eg "Your Money and Life") to inform customers about the range of products and services available to them.

Concerns older customers may have about accessing electronic commerce are heightened if English is the second language. With this in mind, the Bank has ensured the provision of interpreters with the assignment of multicultural staff for non-English speaking groups in key areas.

The Bank is committed to providing equality of opportunity in employment for all its employees including those with a disability. The Bank recognises that selecting employees on the basis of merit, regardless of personal characteristics or circumstances, is an important element in its success and growth.

The Bank recognises that a diverse employee base provides a valuable source of advice and consultation on how products and services can be tailored to meet the needs of all the Bank's customers.

The Bank introduced Disability Contact Officers in 1993 following the introduction of the Disability Discrimination Act in 1992. Each State Administration area of the Bank and Business Unit has a trained Disability Contact officer whose role includes;

• being the link between the Bank and employees with a disability should any issue arise,
• placement and career management of employees with a disability;
• ensuring employees with a disability are provided with the most appropriate employment opportunities,
• organising any special training, equipment, facilities for the person with a disability and any appropriate training for co-workers,
• assisting monitoring of performance of employees with a disability, and

distributing the booklet "Managing Staff with disabilities - information for supervisors" to supervisors.

Coupled with this process, internal training on general discrimination and harassment on the grounds of a disability is conducted frequently, including a quarterly training segment on CBA-TV (the Bank's internal television network). Staff are able to apply this training in their service to the Bank's customers.

The Bank remains committed to supporting community and special needs groups. Existing Commonwealth Bank customers who are unable to use Self Service Banking facilities (eg ATMs) due to a disability are exempt from transaction fees.

In developing this policy, the Bank spoke to a number of groups around Australia representing people with various disabilities. The Head Injuries Council of Australia was one such community group. A subsequent staff training video was prepared, with specific examples of how to deal with customers who have brain injuries and/or dementia who may have problems using self-service banking and/or remembering pin numbers.

At the time of developing the policy, and periodically since, the Bank has run advertisements promoting the Bank's policy in various journals for people with a disability.

A majority of the Bank's existing aged pension and war veteran customers are entitled to a rebate of $6.00 a month which allows additional fee free transactions. This is an extra rebate over and above the existing personal customer relationship rebates, which apply to all our customers, and recognise and reward the value of the relationship which the customer has with us.

The Bank values the feedback it receives from older and disabled persons' organisations. Such organisations play an important role in representing the needs of their membership to the Bank and the Bank, in turn, is able to work in partnership with them to ensure accessibility of a full range of banking services.

The following organisations receive specific sponsorship assistance from the Bank;

• Council on the Ageing
• Australian Pensioners' & Superannuants' Federation
• Link Magazine (for the disabled).

As well, the Bank has sponsored numerous projects in conjunction with the "International Year of OIder Persons'", including the recently announced sponsorship of the Older Australian of the Year award for 2000.

The Bank is aware of the importance of ensuring that people with a disability have physical access to banking services. To that end, the Bank has implemented a number of strategies aimed at providing better access for people with a disability. These strategies commenced prior to the introduction of the Disability Discrimination Act.

In 1994/95 the Bank commenced remodelling its branches. As part of this remodelling Bank officers are able to attend to non cash transaction inquiries from customers, including customers with a disability in an office/studio, rather than from behind a counter.

Nationally, over 300 branches of the Bank have now been fitted out in this manner.

While many customers are now choosing to conduct their banking electronically, the Bank is aware that some customers continue to prefer "face to face" contact. The Bank is committed to maintaining a significant face to face presence, particularly through branches and Bank agencies.

Australia Post and the Commonwealth Bank have been commercial partners jointly providing services since 1916. The Commonwealth Bank is the only major bank which is part of Australia's giroPost service. Moreover, the Bank has a special relationship with Australia Post to allow personal customers to access all their transaction accounts, including passbook accounts, through all Australia Post agents. The Bank is also the only financial institution with an arrangement to provide services through all other postal outlets not on the giroPost electronic network, giving Commonwealth Bank customers face to face access to personal banking through over 3,800 postal outlets.

Recently the Bank announced that it would be extending its banking services available through Australia Post to include business banking transactions. The Bank and Australia Post are conducting a pilot of 30 sites nationally in rural and regional areas.

As Australia's most accessible Bank, the Commonwealth Bank has a commitment to ensuring that all customers, including the elderly and disabled, have reasonable access to banking services.

The Bank has the following points of representation in Australia:

• Over 1,100 branches
• Over 2600 ATMs
• 94,000 EFTPOS terminals
• 135 mobile bankers
• 104 business banking centres
• 3,800 Australia Post Agencies
• 200 Commonwealth Bank private agencies
• Agribusiness specialists

The Commonwealth Bank, as Australia's most accessible provider of financial services, aims to ensure all Australians, regardless of age, mobility or disability, have the opportunity to access its services.

Incorporating new and emerging technologies into existing ways of providing services has always played a significant role in giving customers greater choice.

The Commonwealth Bank led the industry in Australia in the application of "black light signature" technology (introduced in 1969), which represented the first step away from obligating customers to go to only one branch for service. It has since then consistently been a leader in introducing new banking technologies whilst continuing to operate Australia's largest and most geographically diverse branch and agency network for face to face banking needs.

The Bank is conscious of concern about the pace of change, and special education seminars, brochures, videos, audio tapes and sponsorship arrangements are methods by which the Bank provides information to customers about how they may be able to access electronic channels.

Fee-free banking, braille keypads and statements, TTY service, Alt tags, and specially trained staff are examples of additional services the Bank provides to ensure that older customers and customers with a disability are not disadvantaged with the emergence of new technologies and methods of doing banking.

The Bank will continue its longstanding commitment to remain Australia's most accessible financial institution both in geographic spread and range of distribution channels, whilst offering fairly priced products and services.

1. Transaction Preferences, Commonwealth Bank customers

2. Brochure "Banking Made Easy"

3. Videos "Banking with Helen", "Banking with Harry"

4. October 1999 edition of "COTA News" (See back page)