Principles to improve customer access. June 2017

Transcription

1 June 2017

2 The Third Party Access WP has developed s to improve customer access under the Vulnerability Taskforce 5 - Easy for friends and family to support The s apply to legal instruments for third party access: CoP Deputyship Guardianship order (Scotland may also be combined) Intervention Order (Scotland may also be combined) Controllership (Northern Ireland) DWP Appointee Lasting Power of Attorney (Continuing or Combined Continuing PoA in Scotland) Enduring Power of Attorney (granted prior to / can still be issued in NI) General Powers of Attorney Management of Residents Finances (Scotland - intended to be used where other arrangements are not already in place) Access to Funds (aka Intromit with funds) 1. We will provide you with clear, simple and easily accessible information about options that are available UK Finance Presentation Title 01 July 2017 Information about third party access options will all sit together; information provided will be easy to read and easily understood by our customers and anyone with a need to access this information. Information about third party access options available will be offered through all available distribution channels: Brand public websites Telephone Branch network This is an all-inclusive principle for those that offer all three distribution channels Information will be accessible and made available in a variety of formats including hard copy as per firms obligations under the Equality Act as a minimum. We will ensure that information is consistent throughout the organisation, relevant and up to date. We will provide information which colleagues as well as customers can equally and readily access as and when needed, including a link to the OPG website. 2

3 Notes 2. We will make sure that our firm s requirements and process involved to access options available are transparent, and available to consumers and colleagues through a variety of channels. We will be clear about the journey customers can expect and about the requirements to register and operate options available on a single or a joint/multiple basis. Requirements to Register legal instruments ID&AV evidence that may be produced Registration documents e.g. the instrument, other application forms, relevant accounts Acceptable formats We will accept any and all legal documents authorising third parties in the following formats: Originals Copy certified by Solicitor For POA, LPA and EPA documents we will further accept: Copy certified by Donor Copy certified by Notary (as defined in the Power of Attorney Act, 1971) Copy certified by Stockbroker (as defined in the Stock Transfer Act, 1963) On the assumption that the legal instruments do not state any requirements for medical evidence, such evidence will only be sought on an exceptional basis (i.e. suspicion of fraud or financial abuse). Process to Register legal instruments Registration channels available will include: Branch Post A confirmation will be issued to the third party/ies and donor/granter (where they have mental capacity) once the Registration is complete Who can do the Registration (the Third Party/ies will suffice for all existing customers) Signatures required on the Registration documents will only be required from the authorised third party/ies Donor presence or signature to Register a legal instrument where the Donor is an existing customer may only be requested in exceptional circumstances such as where there is suspicion of abuse. This implies that the Attorney can update customer records if needed. We shall aim to minimize the need for donors/granters to attend a branch for Registration of a legal instrument and account opening UK Finance Presentation Title 01 where July 2017 the donor is not an existing customer, as per obligations under the Equality Act and mindful of other vulnerable circumstances. We will consider cases involving foreign delegation documents or third parties living abroad on an individual basis. Notary: granted by the Archbishop of Canterbury, and on Notary Society Register for England & Wales. Stockbroker: member of any stock exchange as per the Act; today this would mean an Independent Financial Advisory (IFA) Exceptions refer to suspicions of fraud or financial abuse in which case OPG referral would be 3 needed.

4 3. Our team will provide support to meet your needs throughout the process 4. We will be transparent about limitations of usage of our products or channels by third parties. We will not present any unnecessary barriers to third party servicing and transacting. UK Finance Presentation Title 01 July 2017 Service is planned to minimize inconvenience and distress We will also tell you about other external sources of help available to you. Specialist support available for colleagues: Front line colleagues will be able to show the necessary empathy, skills and knowledge for their role to provide support. Front line colleague training will include: Empathy (this can be part of wider/vulnerability training) Awareness of any referral process / access to specialist team, or most experienced colleagues, or information The ability to recognise customer needs at front line Cross-skilling to ensure availability Specialist team training: Empathy (this can be part of wider/vulnerability training) Fully trained in all aspects of third party access needs and available options Colleagues to be confident and to have an understanding of the legal instruments Regular training content updates Regular monitoring and testing Ongoing competence: Training refreshers Ongoing observations and assessment of customer outcomes Singly appointed third party: Where there are no restrictions on legal documents registered with us, we will enable third parties to act through all available channels: In branch Over telephone Online This list is meant to be all-inclusive where firms offer all channels to regular customers Multiple appointed third parties: We will be mindful of changing circumstances legislation and jurisdictions We will actively seek for continuous improvement, to develop our policies, systems and current offering of channels available to understand how and where enhancements can be made. 4

5 5. We will make sure that once you ve been in touch, we will notify all relevant points. We will make sure that once you have Registered a document with us, you will not need to Register this again across retail products. We will tell you which points within the business have been notified and support you with the details of other parts of the business, or separate brands, that you may need to register your authority with. There may be few exceptional circumstances where we may ask you to provide additional information even though you have already Registered an instrument with us, for example where regulation requires us to do so, or where we may have concerns about the use of an instrument. 6. We will ensure we consistently provide the best possible service for those who require options for authorising a third party to access their accounts or information about their accounts. We will explore what an industry wide framework for a third party mandate might look like and under what circumstances it could be applied. We will explore with OPG, DWP and respective bodies in Scotland and NI, the possibility for a referral Protocol in cases of suspicion of abuse. UK Finance s to improve customer access 01 July