banking for all

Any form of disability could potentially serve as a barrier to accessing financial services, if the right guidelines, procedures and technologies are not in place. 

When he was 10 years old, Josh Nonet-Black, a consultant in the artificial intelligence and data science team at Deloitte, decided he wanted to open a bank account. However, his age meant that he was unable to access his account online. Without online access, he would need to visit the branch and ask a member of the bank to read out his account details every time he wanted to monitor his account. 

Mr Nonet-Black was born prematurely with detached retinas and has been blind his entire life. He is quick to point out that options for those with sight impairments have vastly improved since his childhood. He is a regular user of online banking and fintech services, such as Nutmeg and Revolut, that work with his online screen reader, helping him to control his finances without having to ask someone to read out sensitive information. 

According to data from the World Bank, more than one billion people — or 15% of the global population — experience some form of disability. In the UK alone, 19% of working-age adults and 46% of pension-age adults are disabled, according to the disability charity Scope. In the US those numbers are even higher, with 61 million Americans (26% of the population) living with a disability.

Disability visibility

What could be classed as a disability ranges from sight and hearing loss to mobility difficulties, cognitive and learning disabilities and mental health issues. And while a lot of people are born with a disability, many more encounter these barriers during their lifetime due to an illness or an accident, or as a natural part of ageing. According to the International Agency for the Prevention of Blindness, 80% of visually impaired people globally are over the age of 50.

You want to make sure that your written communications are accessible

Natalie Ledward, Monzo

The reality is people with a disability are not a small group, but are the general population at large. However, any disability could potentially serve as a barrier to accessing financial services if the right guidelines, procedures and technologies are not in place — especially as these barriers are both unintended and often easily remedied.

There is a wide variety of guidelines and regulations around the world that look at how organisations ensure their services are accessible. Among those are the Americans with Disabilities Act of 1990, which requires US banks and credit unions to give equal treatment to all customers; the Web Content Accessibility Guidelines (WCAG), published in 2008 and aimed at making internet content more accessible, primarily for people with disabilities; and the guidance for firms on the fair treatment of vulnerable customers from the UK Financial Conduct Authority (FCA) published in February 2021. 

Putting people first

The FCA’s vulnerable customer guide was cited by many banks as a benchmark for who should be flagged as possibly having accessibility issues. As with the notion of disability itself, the guide is not black and white, and greatly depends on context. Broadly, the FCA defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.” This clearly encompasses a wide range of people. 

natalie ledward

Natalie Ledward, Monzo

“We obviously focus on vulnerability from a financial perspective and what it means to people’s finances… what we’re talking about is whether that is a total exclusion from the financial system,” says Maxine Pritchard, head of financial inclusion and vulnerability at HSBC. 

Ms Pritchard agrees that there is a difference between those who are experiencing vulnerable conditions and those who may find themselves in a vulnerable position. 

“I’m not saying because somebody has a visual impairment they are therefore vulnerable — that’s very insulting,” she explains. “What I am saying is if we don’t have the right systems in place for people to access the financial system because of their disability, we are making them vulnerable.”

Focusing on accessibility

Following the FCA guidance, other banks are now re-examining their own accessibility issues. Monzo, a UK-based digital-only bank, relies heavily on regular customer feedback sessions. According to Natalie Ledward, its head of vulnerable customers: “We’ve spent the past few months doing a gap analysis and making sure that we really understand where our gaps are, and what we need to address. We’ve got an action plan over the next 12 months to either relaunch or implement changes.” 

Another British bank, TSB, is building on the FCA guidance to ensure its services are accessible, which is very much in line with the strategies of other retail banks. The bank looks at ‘ease of access’, or how customers access branches, applications and other banking services. This has resulted in services such as tactile bank cards, talking ATMs and correspondence in Braille, large print or different coloured paper for people with vision impairment or reading issues, says Neil Mitchell, head of customer risk at TSB.

Communication is an important issue. This looks at the way the bank sends correspondence and makes sure mobile apps adhere to web content access guidelines, adds Mr Mitchell. 

TSB also takes into consideration ‘physical wellbeing’, which concerns those who may have a hidden disability or are experiencing mobility issues. “We have signed up to the ‘Sunflower lanyard’ scheme for people who have no obvious disability,” says Mr Mitchell. The Sunflower Hidden Disabilities campaign was started in the UK in 2016 and seeks to raise awareness of people with disabilities that may not be immediately obvious, such as epilepsy or autism. The Sunflower campaign has now expanded overseas and is available in Australia, Belgium, Canada, Denmark, the Netherlands, New Zealand and the US. 

“Another thing we have done is enable [customers] to register for third parties to operate their account (such as a carer) online and in branch for any customer who can’t actually leave the house, or has some reason they would wish to do it that way,” Mr Mitchell adds.

Many banks and financial firms adhere to the WCAG guidelines for accessibility. Some of the guidance, designed for web and mobile developers, looks at coding and text that could inadvertently make online content inaccessible for people with disabilities. Those include providing alternative text for images, which makes it readable for services such as screen readers. Another example is ensuring that functionality is accessible via the keyboard, for those who are unable to use a mouse with a computer. 

Inclusive by design

People like Mr Nonet-Black rely heavily on the accessibility services that come as standard on his home devices. “My bank has put things in place to make sure that my screen reading software is capable of interacting with their application,” he says. “Actually, this is where it gets interesting, because from what I’ve found, a lot of the new fintech apps haven’t got those accessibility standard regulations in place.” 

Despite being a regular user of Revolut, Mr Nonet-Black says when he first downloaded the application, which allows the user to interact with a virtual card, the card only appeared as an image, meaning that his screen reader was unable to read the details. “It’s things like that which people don’t necessarily think about when designing apps or even a web page,” he adds. 

Many fintech companies design applications for a specific customer group and accessibility becomes an add on. “Fintechs have a business model: to be the first to market with a minimal viable product — whichever name you want to use — but essentially, they need to get there very, very quickly and get a foothold,” says Matthew Luken, user experience design director and vice-president of digital accessibility at US Bank, who stresses this is his personal opinion and not the viewpoint of the bank. 

This observation lies at the heart of the paradox of inclusive design. If the conventional wisdom is to design products that are tailored to the needs of specific groups of people, will that design mindset produce exclusive, rather than inclusive services? 

“I think that both types of organisations have got different challenges to overcome, but we have a large and diverse customer base that we can work with and learn from... that enable us to design accessible solutions and to help people manage their money independently,” says Kat Townsend, head of vulnerability and accessibility at Barclays. “With those economies of scale, you get richer data to work with.”

CaixaBank ATM wheelchair1

Easy access: CaixaBank’s wheelchair-friendly ATM

Universal blueprint

Accessibility needs should be considered from the outset, according to most of the banks The Banker spoke to. “There are statistics out there that show that if you find your accessibility problems when you first run the automated testing, it’s three times the cost to repair,” warns Mr Luken. “If you find it during manual testing, it’s 12 times the cost to repair — and when you move it into production, it’s 95 times the cost to repair.”

“We take into account customers that may have physical or mental barriers, among others, not only at the start, but also along the whole process until product delivery,” says Jordi Nicolau, director of retail banking and customer experience at CaixaBank. “For instance, when our new ATM was developed, we engaged with more than 2000 customers in the understanding phase, including customers with physical, sight and mental impairments, to make sure we were taking their needs into account.”

However, inclusive design should not be confused with universal design, says Bailey Kursar, founder of Touco, a fintech-for-good research lab that provides a financial app for carers. “You cannot design for everybody — that is nonsense,” says Ms Kursar. “If you just think about everyone on the planet, you’re going to end up with very poor design; it’s either not going to meet people’s needs or there might be unintended harm.”

An example of inclusive design, rather than universal design, is focusing on the needs of people “who have needs that are above and beyond your average or ideal user”, says Ms Kursar. “If you prioritise their needs and you put them at the heart, you will uncover issues that can actually apply to lots of other different needs... by getting into the complexity of it at the start, you actually create better design for all.” 

Good design

One example of design tailored for a specific group with wider benefits is around language and what Monzo Bank calls “tone of voice”. Most of the banks that spoke to The Banker discussed re-examining the language used in banking documents, removing complexity and reducing the reading level. These actions were intended for people with cognitive impairments or learning difficulties. However, using simple language in financial communication is something that is welcomed by many, even those with high levels of reading comprehension. 

If you just think about everyone on the planet, you’re going to end up with very poor design

Bailey Kursar, Touco

“Our tone of voice is basically a piece of guidance that we use as our ‘go to’ whenever we’re writing any copy,” says Ms Ledward. “It turned out to be quite a universal piece of work in the end. Whether it is communications, by email to a customer, or within the app, the aim of it was to reduce the reading age of all our materials. You want to make sure that your written communications are accessible.”

That emphasis on simplifying content is echoed at many other banks — not only in written communication, but also personal interactions. Barclays takes time to support customers if they need a quiet space, more time, a longer appointment or anything rephrased, says Ms Townsend. “Our colleagues are supported through training and development to recognise those needs as well,” she adds.

Simplicity has universal appeal. “What we’re focused on is what is the simplest thing to do for the customer [and] what is the best way to support them with what it is that they need?” says Jemma Waters, head of responsible transformation at Lloyds Banking Group. “They want information clearly and concisely, and in a way that they can take action and feel comfortable with.” 

Raising awareness

However, not all accessibility tools can be used by everyone experiencing the same disability. Not everyone who is blind can read Braille, and not everyone who is deaf uses British sign language, for example. Many of these barriers appear with people as they age. In the UK, around 79% of people living with sight loss are over the age of 64, according to the charity Fight for Sight. However, many of these people will not start learning Braille in old age, says Joe Devon, co-founder of Los Angeles-based Diamond, a digital agency specialising in web and mobile applications and founder of Global Accessibility Awareness Day.

A software developer, Mr Devon became focused on accessibility after witnessing his father become excluded from banking services. His father, a Holocaust survivor who spoke 10 languages, started to lose his eyesight and hearing. “Going to the bank, for him, was an all-day affair because he had to use a special-access [community transport] to get to the bank, as the telephone didn’t work for him because he couldn’t hear,” he says.

bailey kursar

Bailey Kursar, Touco

Mr Devon thought the web would be the solution to his father’s problems. “But the banking website was inaccessible,” he says. “I got really upset because my dad had to go to his kids in order to do his banking. What a shame that is.” 

Because of this experience, Mr Devon wrote a blog post proposing a Global Accessibility Awareness Day. The post went viral and the campaign is now in its 10th year. He later received correspondence from the bank his father dealt with, saying that they used the day as a catalyst to work internally with staff to improve their accessibility issues.  

Without examining the nuances in accessibility, certain procedures, services and regulations can end up affecting individual people in harmful ways that are often unintended. 

John Ciocca, a senior at Florida Gulf State University, was driven to found Purple, a US-based fintech aimed at people with disabilities, after his brother’s bank account was closed. His brother Christian, head of community at Purple, was born with Down’s syndrome. 

People with Down’s syndrome in the US qualify for supplemental security income (SSI) benefits. However, there are strict income limits associated with SSI, including not earning more than $750 per month and not having more than $2000 in saved income or available assets. Because of that, John Ciocca says, many people receiving SSI benefits — like his brother — drain their bank accounts every month to keep in line with US regulations. This led to his brother having his bank account closed because he could not keep up with the minimum monthly balance requirements. This cap on earnings and savings also inhibited the ability for his brother to stay in paid work, which was essential to maintaining his mental wellbeing. 

Disability is not a niche issue, but a range of issues that have the possibility to affect large swaths of the population at any point in their lives. This is something that affects billions of people — all of whom live with the possibility that something they are born with or experience may cause them to be excluded from secure, regulated financial services, unnecessarily. 


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