| Yes/No/Partial | Yes/No | |
Commonwealth Bank of Australia (also answered on behalf of Bankwest) | Yes – specialist teams with trauma-informed training. Customer care guide includes section on financial abuse including elder abuse. Mandatory training modules, including financial abuse, for customer-facing roles. | Yes – 1500 per year | Use of Artificial Intelligence (AI) to detect cases of financial abuse. Technological tools to secure accounts. Will have to monitor developments in impact of digitisation. |
Afterpay | Partial – account frozen if payments missed, financial hardship program, and financial counsellors available. | No – number of financial hardship cases is < 0.5 per cent of customers | Digital-only platform includes communication channels which could manipulated to facilitate financial abuse. |
Allianz | Yes – commissioned Gendered Violence Research Network through UNSW. Training to identify family violence and escalation to high care team. Flexibility to pay claims from wrongful conduct of other in family violence situation.Consideration of financial abuse in product development. | Yes – 35–50 customers per month experience vulnerability. 90 per cent of those impacted by family violence. | Considering risks and opportunities of online platforms. Masking contact details on online portal if identified as vulnerable. |
AMP | Partial – policies cover areas which may indicate financial abuse. Reference guides to family violence implemented through mandatory training for customer-facing staff. | No | Use of AI to identify financial abuse. Planning to consider impacts in 2024 thematic review. |
ANZ | Yes – training to identify signs of family violence and financial abuse. Home loan interview guide includes check on presence of financial abuse amongst co-borrowers. Analysis of payment transaction data to identify abusive transactions. Specialist team to support customers subject to domestic violence and financial abuse. General hardship arrangements. Piloting data analysis to identify abuse of power of attorney. | Yes | Statistically unclear based on data reviewed. Commenced incorporating AI and automation to identify instances of financial abuse. |
Australian Military Bank (COBA) | Partial – general vulnerability training includes elder financial abuse and family and domestic violence. Staff trained to detect financial abuse and to escalate to specialist team. | No – described as rarely reported. | Implementing rules and tools to mitigate digitisations risks. |
AustralianSuper | No – general measures to prevent unauthorised withdrawals and transfers. Emotional intelligence training in insurance claims assessors. | No – family related fraud cases 3 per cent of all fraud cases. | Enhancing security protections to mitigate digitisations risks. |
Auswide Bank | Partial – general vulnerability policy. Staff learning modules include domestic violence. Staff reference guide includes warning signs of financial abuse and how to escalate. | No - 48 customers flagged as vulnerable as of 21 June 2024. | No response |
Bank Australia | Yes – financial abuse guidelines for detection handling and resolution of potential instances. Annual training for protecting customers from financial abuse. Specialised customer care to handle complex cases. | Yes – 44 active cases of financial abuse as of 20 June 2024. | Provide information to customers on how to secure accounts. |
Bank of Queensland | Yes – training to recognise and respond to financial abuse. Weekly monitoring of abusive language in payment transfer descriptions. Terms and conditions updated to permit closing accounts in such cases. Language interpretation services covering 190 languages. | Yes – 228 cases detected in 2022 and 2023. | Amid a transformation program to respond to digitisation. |
Bank of Us | Partial – information for staff on warning signs and reporting of elder abuse and financial abuse. Name change process considers vulnerable people. | Yes - have been instances of concern for potential financial abuse. | Difficult to balance individual’s rights to bank online without questioning with consequences of unidentified abuse. |
Bank Orange | No | Yes – described as minimal instances. | Harder to monitor transactions. |
BankVic | Yes – terms and conditions disallow financial abuse. Tracking transaction descriptions with abusive language. General mandatory staff training on vulnerable member and specialist support team available. | No response | No response |
BankWAW | Partial – guidelines for accounts operated by powers of attorney and authority to operate. Annual online staff training on financial abuse. COBA financial abuse practices. | Yes – identify and escalate cases suspected upon interactions with customers via phone or in person. | Card misuse difficult to identify with careful perpetrators. Can enforce verification before purchases, however, may be unpopular with customers. |
Bendigo and Adelaide Bank (also responded on behalf of Up Bank) | Yes – vulnerable customer and financial abuse policies. Flags made in systems to note vulnerable customers. Specialist teams aware of flagged customers’ situations. Deferred loan repayments available. Vulnerable customers can set up new account despite not having access to identification. Specialist team established is trauma informed. Tracking of abusive transaction descriptions. Terms and conditions enable cancellation of perpetrator’s account. | Yes – 8127 cases of financial abuse or domestic violence since 2018. | Understanding of domestic and family violence has improved. However, technology may act as mechanism for abuse, such as through transaction descriptions. Require more development in understanding of how to respond to digitisation. |
Beyond Bank | Yes – prevention of financial abuse policy and procedure. Customers can ‘ask for Angela’ to discretely notify staff of vulnerable situation. Specialised advice on misuse of power of attorney as well as supporting evidence requirement for applications. Bi-annual vulnerable customer training, including financial abuse. Prescribed questions in cases of account action with potential coercion. Hardship measures so victims are not reported to credit agencies. | Yes – 15 individuals used ‘ask for Angela’ flag. 39 individuals have indicated they are experiencing domestic violence. | Recognise importance of face-to-face and considerate communication to identify cases. Implemented facial identification to combat perpetrators’ access to accounts. |
BNK Bank | Partial – financial hardship policy includes responding to financial abuse circumstances. | No | Recognised difficulty of recording customer data on suspicion of financial abuse as opposed to disclosure. |
Defence Bank | Partial – staff training on vulnerable customers. Transaction monitoring to identify potential financial abuse. | No - two potential cases identified which were determined as not financial abuse. | No online security gaps identified. |
G&C Mutual Bank | Partial – general hardship policy for vulnerable customers. Education of members through newsletter and website articles. Customer facing roles trained on identifying financial abuse red flags. Centralised team aware of financial abuse cases. | No | Easier to identify financial abuse when customer is physically present. Online platforms cause difficulty in identifying abuse. |
People First Bank (merged with Heritage Bank) | Yes – customer care procedures include identifying and responding to financial abuse. Customer facing roles trained on identify instances of financial abuse. Limitations in place for Power of Attorney cases. Customer care specialists have expertise in managing financial abuse cases. Record keeping to note customer needs. | Yes – 299 suspected cases. | Alerts for threatening or controlling messages sent to customers. Automated processes such as account freezing should be enacted cautiously to prevent vulnerable customers losing access to funds. |
HESTA | Partial– General vulnerable customer policy which includes domestic and family violence. | No | No response |
HSBC | Yes – guidelines for preventing and responding to financial abuse. Specific training on financial abuse. Extra care team to help customers explore options to alleviate circumstances. Terms of condition prohibit perpetrators of financial abuse. | Yes | Online access to escalation to extra care team. Monitoring payment messages. |
Hume Bank | Partial– General vulnerability policy. Staff training includes financial abuse. Product disclosure statement prohibits financial abuse. | Yes – isolated instances of suspected cases. | Increased visibility of financial abuse as well as potential for exploitation. |
IMB Bank | Yes - Financial abuse training module. Procedures for detecting and escalating cases of financial abuse. Compliance review by legal team before acting on power of attorney. Register of suspected financial abuse. Terms provide IMB to end power of attorney or close accounts in cases of financial abuse. | Yes | Online products enable access to victims’ accounts by perpetrators. |
ING Bank | Partial - identification of abusive messaging. Specialised care team available to investigate cases. Joint account fund transfer approval requirements. Consideration of how to safely contact customer when financial abuse is suspected. | Yes – increase in number of cases identified. | Increase in channels for perpetrators to abuse as well as opportunities for banks to better identify and respond to cases. |
Latitude Financial | Yes - mandatory vulnerable customer training includes financial abuse. Hardship team undergoes financial abuse training through National Debt Hotline. Customers experiencing financial abuse are not required to provide documentation for hardship applications. Can provide security assessments for no charge. | No | Can identify and respond to financial abuse despite digitisation of services. Considers that there are difficulties in detecting abuse in person as it may not be obvious. |
Liberty | Yes – teams follow model to recognise, respond to and refer cases of financial abuse. Assessment of beneficiaries in joint loan applications. Protections on contact information and credit files of victims. Loans with identified financial abuse are flagged and details recorded. | Yes – some cases identified through financial counsellor referrals. | No response |
Macquarie Bank | Yes – vulnerability policy includes financial abuse. Training on financial abuse for customer facing staff. Escalation process to specialist care team. | Yes – instances have been small proportion of customer base. | Online banking requires multi factor authentication for some transactions. Identification of abusive language in transaction descriptions. Staff training on identifying vulnerable customers through online chat function. |
MyState Bank | Yes – staff trained in managing financial abuse. Vulnerable customer and financial abuse procedures. Identified vulnerable customers flagged. | Yes – 15 instances of financial abuse over last two years as of 3 July 2024. | Monitoring of abuse in transaction descriptions. Investing in digital risk management to improve identification of potential financial abuse. |
NAB (also answered on behalf of ubank) | Yes – specialised customer care team. Bankers trained in identifying domestic violence and elder and financial abuse. Escalation process to enforcement bodies. Terms and conditions describe financial abuse as unacceptable account conduct, allowing cancellation of perpetrators’ accounts. Increased supervision of cases with concerns of misuse of power of attorney | Yes – 370 000 transactions with abusive text blocked since 2022. | Have made policy changes to prevent abusive transactions and prevent unacceptable conduct. |
Newcastle Greater Mutual Group (answered on behalf of Newcastle Permanent and Greater Bank) | Partial – vulnerable customer framework. Terms and conditions permit cancelling payment facilities, accounts or new accounts in cases of abuse. Monitoring transaction descriptions. | No | Require continual investment in supporting vulnerable customers. Voice biometrics using artificial intelligence to identify customers in distress. |
Police & Nurses Bank | Yes – Mandatory training on financial abuse indicators. Separate accounts made in cases of domestic or family violence. Checks in place for accepting, registering and acting on powers of attorney. Assessment of beneficiaries of joint loans. Internal working group for customer support informed by Centre for Women’s Economic Safety. | No – as of 3 July 2024, have plans to finalise data collection methods in the next three months. | Digital payment channels can create digital footprint of abusive behaviour. Collaborating with vendors to implement technology to detect financial abuse in online platforms. Using artificial intelligence to detect financial abuse. |
Prospa | Partial – staff trained to identify signs of financial abuse and escalate to fraud team. Systems to review bank statement data. Ending liability of victim in identified cases of financial abuse. | Yes | Use of identification tools such as Director ID and ATO Tax Portal to prevent spouse access. |
Queensland Country Bank | Yes– Vulnerable customer policy includes financial abuse. Policy provides guidance for identifying financial abuse. Confidential register of vulnerable members. | No – obtain data on vulnerable members but do not distinguish type of vulnerability. | Transaction monitoring software implemented. |
Regional Australia Bank | Partial – staff training includes financial abuse. Conditions of use allow action in response to financial abuse. | Yes – 50 active cases of financial abuse. | Transaction description monitoring. Greater investment in technology required to identify abuse. |
Southern Cross Credit Union | Yes – independent review of applications for power of attorney. Assessment of beneficiaries of joint loan. Policies and regular training on identifying and responding to customers experiencing financial abuse. | Yes | No impact identified. |
Summerland Bank | Yes– Program to assist vulnerable customers covers elder financial abuse, misuse of power of attorney, domestic violence, psychological and physical disability, poor financial literacy and young people. Vulnerable customers committee for developing program and training employees. Additional transaction monitoring of high-risk customers. | No – five cases of power of attorney abuse and three cases of elder abuse. | Transaction monitoring aids in identifying abuse. Reporting to police/government departments in NSW difficult due to privacy legislation. |
Suncorp (answered on behalf of AAMI, GIO, Suncorp Insurance) | Yes –Training for customer-facing employees on dealing with vulnerable customers. Mutual consent required for joint policy changes. Customer profile flags and consensual recording of vulnerabilities. Changes to policy in domestic violence or elder abuse cases must be actioned by specialist team. Partnered with Uniting’s CareRing referral service. Conduct of others clause to protect customers affected by perpetrators. | No – do record financial hardship, family violence or elder abuse. | Highlighted that as an insurance provider, fewer digital channels for communication available between perpetrator and victim. |
Teachers Mutual Bank | Yes – Vulnerable persons policy and training. Guidelines for powers of attorney including power to refuse application. Connecting customers with third-party agencies. Flagging vulnerable members in system. | No - small percentage of customers flagged as vulnerable relative to customer base. | Human interactions most effective in identifying financial abuse. Implemented monitoring transactions for verbal abuse and AI call monitoring for vulnerability. Self-service tools for customers to action online accounts are available. Provisions allow withholding account information from joint account holder if abuse is suspected. |
The Capricornian | Yes – financial abuse of a vulnerable member policy. Online transactions reviewed for potential abuse. Training on how to recognise and respond to financial abuse. | Yes – 5 suspected cases resulting in 3 investigations concluded as financial abuse. | Issues with lack of assistance from third parties. |
Transport Mutual Credit Union | Yes – financial abuse policy and procedures. Policy includes identifying, reporting, escalating, investigating and resolving financial abuse cases. Staff trained on various forms of financial abuse. Management encouraged to consult with external agencies. | Yes – identified two cases with financial or elder abuse characteristics. | Safeguards in place to respond to financial abuse are more pertinent than digitisation. Regulations should consider size of financial entity to maintain competitiveness of smaller businesses. |
Unity Bank (also answered on behalf of Reliance Bank) | Yes – policies include identifying potential financial abuse and ensuring caring and culturally appropriate support. Record keeping and reporting of financial abuse. Training for combating financial abuse is available. External support services are made available. | No – 34 current vulnerable customers with 5 relating to elder abuse and most being victim survivors of domestic and family violence. | Impact of digitisation is minor. Have maintained highly personalised services. Risks of online de-personalisation of services is outweighed by advances in detection technology. |
Westpac | Yes – Customer vulnerability framework includes financial abuse. Standards outline Recognising, responding to, recording and referring vulnerable cases. Extra care flags to inform future interactions. Monitoring of abusive language in transaction descriptions. Terms and conditions prohibit abusive descriptions. Monitoring of and restrictions on power of attorney arrangements. Provision of emergency funds in cases where safety is jeopardised. | Yes – 4597, 6957, 8892 and 11 894 cases of potential financial abuse from 2020 to 2023. Noted increase in cases over years. Over 140 000 transactions with abusive language blocked since 2020. Power of attorney arrangements currently in place for 150 000 customers. Havereceived25 031 alerts since 2023 through monitoring. | Digitisation has created new channels for financial abuse. Steps taken to ensure harm-reduction are critical. Digitisation allows for more detection and monitoring of some abuse. However, Data-led approach may omit individual cases’ complexities. Assessment by human interaction remains critical. |
Wisr | Partial – several points in loan process allow identification of financial abuse – application, missed repayments and requests for financial assistance. Assessment of mutual benefit in joint loan applications. Reviews of account to identify financial abuse flags. No interest repayment breaks in some cases. Suppression of RHI credit reporting on victims in joint loans. | Yes – from January to June 2024, 23 cases related to domestic violence identified, mostly having financial abuse characteristics. | Has been a digital lender since establishment. Continiously improve controls and processes to identify financial abuse. |
Zip Co | Partial – no joint accounts available. Transaction monitoring can identify financial abuse. Training on how to respond to claims of financial abuse. Hardship team trained on identifying family violence and financial abuse. Domestic violence and hardship support policies developed with Good Shepperd. | No – during the 2024 financial year 978 customers requesting hardship assistance were identified as vulnerable. | Has been an online business since establishment, therefore cannot comment on impact of digitisation. |