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Gillian Guy speaks at BBA Retail Banking Conference 2017

Chief Executive of Citizens Advice Gillian Guy
At the recent BBA Annual Retail Banking Conference in June, our Board member, Citizens Advice Chief Executive Gillian Guy spoke on giving a voice to those who need the banking industry’s help and support, touching on issues of trust, loyalty and vulnerability.
Gillian has given kind permission for us to reproduce her speech below.


Thanks to the BBA for affording me this slot – and so highlighting the need to give voice to those who need the banking industry’s help and support.

I hope that Citizens Advice is well known to you – principally, I expect, for giving advice and support to millions of people each year – many of whom are especially vulnerable.

Possibly less well known will be the fact that we give advice to an extremely wide range of people – particularly regarding debt and consumer issues – encompassing your customers , your would-be customers and probably not insignificant numbers of your staff.

And we take the evidence from those millions of people and highlight major issues for consumers and where appropriate seek redress. Not sure if I should remind you here that it was Citizens Advice who made the original super complaint about the mis-selling of PPI. which, as you know, led to over £24 billion being returned to consumers.

More than that though – we look to identify changes in policy and practice to fix problems and stop them recurring and we work with Government, regulators and the industry (including the BBA and Banking Standards Board ) to make them happen.

At Citizens Advice we have the insights that can help you succeed for your customers.

And it is in all our interests to use them to good effect.

We see at first hand processes and practices which result in detriment – often to those who are least able to withstand it.

At a deeper level, we see a more profound cultural challenge.

And a need for social purpose commensurate with the responsibility of providing an essential service – and enjoying a significant share of the balance of power.

Today, I want to talk about the relationship of banks with customers, vulnerable and not – and with wider society. And I want to give a couple of examples which undermine it.

And I want to start with trust.

The banking industry has a clear sense that it does not hold the position in society it once did. This is often expressed by asking why the public no longer trust or understand it and has led to a bit of a mission – to regain or rebuild trust.

In my view – it is a search to recover something you never truly had. I believe we have mistaken deferential treatment (based on faith – or sometimes, fear ) for trust – which is far more of an emotional buy – in.

It is true that bad things happened ( and indeed continue to ) which seriously damaged the image and reputation of the industry – but there was a broader change going on too.

Banks – along with others – (even doctors and lawyers!) suffered a loss of deference attached to their positions of authority – as consumer confidence and expectations of service providers, massively increased.

Instead of harking back to times past, I think we need a re-set on two fronts: firstly – addressing the question – what are banks for and what social responsibility do they carry?

This goes to the heart of a responsibility that comes with the unique territory occupied by financial services – which is far wider than the business, the shareholder interest and the customer relationship.

Happily, social purpose and social value are the subjects of a live debate and the tone is shifting.

But, I am afraid that large sums of money spent on soft focus advertising, claiming at once to be best friend and guardian only fuel deep scepticism with exaggerated sentimentality and sincerity.

And the old cliche holds true actions speak louder than words.

A higher purpose should be evidenced:

  • by how you choose to use your deep – sometimes intimate – understanding of consumer behaviour – to help – not exploit.
  • by the transparency and clarity of communications and terms and conditions – so consumers can make informed choices.
  • by what you do proactively to move people to better deals
  • by your offer of support and advice to avoid early warning signs developing into problems

And by targeted support and protections for your most vulnerable customers. This is not to take away from individual personal responsibility, but gives consumers a fighting chance to exercise it.

The second front is to establish that the industry is trustworthy.

At the heart of being trustworthy is openness and honesty.

Put at its simplest this amounts to – say what you mean and do what you say.

I’ll give you a couple of examples where we see this lacking – in the areas of vulnerability – and loyalty – and a not so sweet spot where the two collide.

Everyone wants a piece of vulnerability and it’s a good focus to have. It brings about some very good initiatives.

We were hugely encouraged by many of you picking up the issue of financial abuse and really examining your processes to thwart this behaviour.

But when it comes to basic bank accounts, ID and verification and overdraft charges, the emphasis has been on process and protection with little attention to the impact on individuals.

We still see products that are structured in a way that delivers higher prices and detrimental treatment to vulnerable people.

Customer loyalty is an issue of great concern to us and it should be to you, Loyalty is laden with sentiment and value judgements. But loyalty is supposed to be rewarded.

People who stick with a provider expect to be put first.

Unfortunately at Citizens Advice we all too often see the opposite. Longstanding customers paying more, and being treated worse, than new ones.

Next month we will report on the fate of loyal customers whose fixed rate mortgages come to an end – it’s not a pretty picture. For example, 85% of people on standard variable tariffs would be better off on a fixed deal.

And here’s the double whammy – business models that penalise loyalty also punish vulnerability. Because it’s your older, less educated, lower income, mentally and physically disabled and distracted customers who are most likely to be disengaged.

The current accepted narrative is that the answer is switching. And that can work for people. But, for some people, particularly the most vulnerable, it’s doesn’t work at all..

And it’s not a solution in itself. It puts the onus on the customer but It doesn’t absolve the industry of responsibility.

And why should you care enough to take action?

You will have worked out the competitive advantage angle – add to that – staying ahead of the regulator.

In the last few years regulators have investigated the current account market, the savings markets, the credit card market, the mortgages market, the annuities market…

The list could go on. And it can’t be right that our ‘world-leading’ financial services sector has to be told what to do by a regulator about things as simple as giving people clear information.

Voluntary action prompted by responsibility and integrity is far more effective – and results in a race to the top rather than bottom – (as I would argue happened in the end with basic bank accounts). It also puts the emphasis rightly on motivation rather than compliance.

And you should care so you can turn the potentially onerous social responsibility to your advantage, to shore up the fragile reputation of the industry and lay those foundations for trustworthiness.

Challenge: new body, new opportunity

As we sit here – we are on the verge of launching your new trade body – indeed – only I stand between you and the new Chair!

I have already picked up two key messages from UK Finance -consumers will be at its heart and it will not defend the indefensible.

That is a brave stand for any trade association and to be applauded – It should herald and support a new shake up within the industry.

At Citizens Advice we wish UK Finance well and stand ready to help them – and all of you – in that endeavour.


Senior Managers and Certification Regime

Exploring how the SMCR - and especially Certification - can be implemented in the most effective way across the sector.

The Senior Managers and Certification Regime is a major regulatory change that will affect all banks and building societies. Responding to recommendations by the Parliamentary Commission on Banking Standards, the government and regulators have together developed a comprehensive framework to ensure better accountability and responsibility for behaviour, competence and culture in banks and building societies. The new framework provides an opportunity for the industry to focus on and demonstrate a culture of professionalism. We are working with firms and regulators to facilitate this, including areas where a common approach across firms could support both the objectives of the regime and the skills and development of the people covered by it.


Evaluating whether a more 'professional' approach to banking would improve behaviour and competence across the industry.

The Parliamentary Commission on Banking Standards found that 'banking culture has all too often been characterised by an absence of any sense of collective responsibility to uphold the reputation of the industry', and argued that a greater focus on professionalism could be an answer to this. Working with a leading team at the University of Leeds, we are researching the issues around professionalism in banking. In particular, we are reviewing how professional qualifications are currently used across the sector, and at whether a stronger role for professional bodies, along the lines seen in some other sectors, like medicine or law, would help raise standards. To inform this work and develop a rounded picture of 'professionalism' and what it means in banking, we are surveying banks and building societies, professional bodies and a wide range of other interested groups, including consumer bodies and investors.


Providing an honest and impartial assessment to Boards of progress against objectives on behaviour, competence and culture.

The BSB assessment exercise presents Boards with an objective and impartial view of their firm's culture, identifying where things are working well and recommending areas for improvement. It draws on information not only from Boards and senior teams, but also from employees, investors (or members), trade unions, customer groups and other relevant bodies. In doing so, it will provide constructive challenge to each firm individually, while building a collective understanding of common issues across the industry, or sectors within it. We undertook our first annual assessment exercise in 2015 with ten firms (Barclays, Citi, HSBC Bank, Lloyds Banking Group, Metro Bank, Morgan Stanley International, Nationwide, RBS, Santander UK and Standard Chartered). The BSB itself will not publish individual assessment reports - each firm owns its own report - but key themes and messages will be set out in the BSB's annual report, the first of which will be published in Spring 2016. Given that Board engagement is central to the assessment work, only firms that have their headquarters in the UK are eligible for the full assessment exercise. All firms, including branches of firms headquartered overseas, will however be included in a focused membership-wide survey, which will allow each participating firm to benchmark itself against its peer group.



If your bank/building society has not responded adequately, or in time, to a complaint that you have already made, you can register your complaint with the Financial Ombudsman Service. Which offers a guide on consumer rights when taking a complaint to the Financial Ombudsman Service.


If you have a problem or query relating to your financial affairs, or are seeking personal finance advice or guidance, there is free, impartial information available from the following organisations:


If you work in the financial services industry and are concerned about any activities conducted by your employer or any other firm or individual, you may find the Financial Conduct Authority and the Prudential Regulation Authority's guidelines on whistleblowing helpful. It explains what constitutes whistleblowing, and what procedures are in place to respond to blow the whistle and how your anonymity would be protected. Public Concern at Work, the whistleblowing charity, also offers support and advice to individuals and employers about how to report concerns and how to establish whistleblowing frameworks.


If you are seeking the services of an independent financial adviser, Unbiased may be able to help, or if you are looking for more general financial guidance, the Money Advice Service may be a useful place to start.