Financial services provision and the prevention of financial exclusion Overview Paper March 2007 Contents Contents ............................................................................................................................. 2 1 What is financial exclusion? ..................................................................................... 3 1.1 Access to what?................................................................................................... 4 1.1.1 Banking exclusion - transactions ................................................................ 4 1.1.2 Savings ........................................................................................................ 5 1.1.3 Credit exclusion .......................................................................................... 6 1.1.4 Insurance ..................................................................................................... 6 1.2 Access or usage? ................................................................................................. 7 1.3 Are there degrees of financial exclusion? ........................................................... 7 1.4 Individual, family or household exclusion? ........................................................ 8 1.5 Conclusion .......................................................................................................... 9 2 Levels of financial exclusion ................................................................................... 11 2.1 Levels of financial exclusion across the EU 15 countries ................................ 12 2.2 Levels of transaction banking exclusion across the EU 15 countries ............... 13 2.2.1 Ireland ....................................................................................................... 14 2.2.2 Italy ........................................................................................................... 14 2.2.3 Spain ......................................................................................................... 15 2.2.4 United Kingdom........................................................................................ 15 2.3 Levels of credit exclusion across the EU 15 countries ..................................... 16 2.4 Savings across the EU 15 countries .................................................................. 17 2.5 Conclusion ........................................................................................................ 18 3 Who is most likely to be financially excluded? ..................................................... 19 3.1 Variations in the types of people who are financially excluded across EU 15 countries ........................................................................................................................ 21 4 The causes and consequences of financial exclusion ............................................ 24 4.1 An overview of the causes of financial exclusion ............................................ 26 4.2 Links between financial exclusion and social exclusion .................................. 30 4.3 Links between financial exclusion and over-indebtedness ............................... 30 4.4 The consequences of financial exclusion .......................................................... 31 4.4.1 Banking ..................................................................................................... 31 4.4.2 Credit......................................................................................................... 32 4.4.3 Savings and asset building ........................................................................ 32 5 Existing policy approaches to financial exclusion ................................................ 33 5.1 Market responses .............................................................................................. 33 5.1.1 Niche providers ......................................................................................... 33 5.1.2 Development of new products and services by mainstream providers ..... 34 5.2 Voluntary charters and codes of practice .......................................................... 35 5.3 Government intervention .................................................................................. 37 5.3.1 Government as facilitator .......................................................................... 37 5.3.2 Government as legislator ................................................................................. 38 5.4 An overview of responses across EU countries ................................................ 39 5.5 Summary and next steps ................................................................................... 39 Annex I – Types of financial exclusion ........................................................................ 47 Annex II - A synthesis of the main experiences of responses ...................................... 48 2 1 What is financial exclusion? The term financial exclusion was first coined in 1993 by geographers who were concerned about limited physical access to banking services as a result of bank branch closures (Leyshon and Thrift, 1993). Throughout the 1990s there was also a growing body of research relating to difficulties faced by some sections of societies in gaining access to modern payment instruments and other banking services, to consumer credit and to insurance. There was also concern about some people lacking savings of any kind. It was in 1999, that the term financial exclusion seems first to have been used in a broader sense to refer to people who have constrained access to mainstream financial services (Kempson and Whyley, 1999). Since then, a number of commentators have added their views of how financial exclusion should be defined. These include both academics (for example, Anderloni, 2003; Anderloni and Carluccio, 2006; Carbo et al, 2004; Devlin, 2005; Gloukoviezoff, 2004; Kempson et al, 2000; Sinclair, 2001); and policy makers (Treasury Committee, 2006a, 2006b; HM Treasury, 2004). The general consensus is that it refers to people who have difficulty accessing appropriate financial services and products in the mainstream financial services market. Two aspects of this definition are important: First the reference to appropriate products and secondly to the mainstream financial services market – as much of the exclusion appears to arise from a failure of the mainstream commercial providers to supply a range of products and services that are appropriate to the needs of all sections of society. There is also a widespread recognition that financial exclusion forms part of a much wider social exclusion, faced by some groups who lack access to quality essential services such as jobs, housing, education or health care. Financial exclusion is, however, a complex concept and the following key issues need to be considered: Exclusion from which financial services and institutions? Do we need to draw a distinction between access to financial services and usage of them? Are there degrees of financial exclusion and, if so, how to express these? For whom do we measure access: the individual, the family or the household? We address these issues in the sections below. 3 1.1 Access to what? One of the key considerations is whether we are concerned with access to services or to specific types of institution. This is a relevant consideration to all areas of financial services and generally the focus to date has been on a combination of the two – in other words access to appropriate services from mainstream providers. This debate is especially important in the area of unsecured consumer credit and in countries where there is a growth in sub-prime (or non-status) lending at a much higher cost and often inferior terms and conditions. The second key consideration is which services are to be considered essential and therefore ones to which all in society should have access. The World Bank (1995) identifies four key areas: transaction banking; savings; credit and insurance (see appendix 1 for definitions, additional information and key issues involved). 1.1.1 Banking exclusion - transactions In parallel with these more general debates about financial exclusion, there has been a parallel discussion about the extent of engagement with banking services in particular. This has arisen for a number of reasons. First, access to banking – and especially to transaction banking services - is seen as a universal need in most developed and, increasingly, cashless societies. Secondly, if people have any products at all, it is generally a bank account or its equivalent. Consequently access to a bank account is seen as an entry point for use of financial services more generally. Thirdly, without a transaction bank account, it is very difficult indeed to access other financial services offered by mainstream providers such as consumer credit, mortgages, or insurance as payments for these normally require electronic payment from a bank account. Finally, in societies that are moving away from cash as a means of payment, it becomes more difficult and expensive for people who can only pay in cash. For these reasons, there has been concern about the extent to which people have relationships with banking institutions, which gives them a means of: receiving regular electronic payment of funds such as wages, pensions or social assistance converting cheques or vouchers into cash storing money safely until it needs to be withdrawn paying for goods and services other than in cash paying bills electronically making remittances While the first three of these can be met through a simple deposit account of some kind, the others are only available to someone with access to transaction banking services. This has given rise to a number of categorisations of the extent to which people are engaged with banking. These include the ‘unbanked’ who are generally taken to be people with no banking relationship at all, the ‘under’ or ‘marginally’ banked who are 4 people with a deposit account that has no electronic payment facilities, no payment card or cheque book an d no means of remitting money. People who do have these facilities but make little or no use of them are also sometimes considered to be ‘under’ or ‘marginally’ banked. As the term ‘under-banked’ implies a value judgement about the level of banking that is appropriate, we believe it is more appropriate to refer to people as ‘marginally banked’. People are considered ‘fully banked’ if they have access to a wide range of transaction banking services that are appropriate to their needs and socioeconomic status (Anderloni and Carluccio, 2006; BMRB, 2006; Barr, 2004; Corr, 2006; Kempson, 2006). Finally, it is important to note that because access to banking services is so fundamental, it is sometimes used by policy-makers and others as a proxy measure for financial exclusion more generally. 1.1.2 Savings The situation with savings is quite different from other financial services. Here there is no discussion of people who are ‘savings excluded’ – largely because gaining access to a simple deposit account does not pose many problems, on the whole. Even so, as we discuss below, some people cannot open accounts because they lack appropriate identification documents and there are problems of self exclusion, not just through lack of money to save but also because of psychological barriers to using a financial institution and a lack of interest in opening a savings account that does not also offer an overdraft facility (see section 4.1 for a fuller discussion of the causes of financial exclusion). Turning to longer-term savings, the ageing population of Europe means that there is a growing need for individuals to make their own financial provision for their retirement. In some countries, with relatively generous state pension provision, this is little more than a debate. In others such as the UK, Italy and France, private pensions are already a necessity if people are to have an adequate standard of living in their old age. Although there is widespread concern about the low levels of private pension-holding among people on low incomes, women and self-employed people (see for example Turner commission in the UK, Brambilla commission in Italy, Commissariat General au Plan in France), pension provision is seldom considered as part of the wider financial exclusion debate. The pensions debate mainly relates to the reform of welfare systems in the light of the ageing populations in industrialised societies. In particular there is a concern to achieve a balance between the need to improve the solvency of public welfare system through longer active working lives and higher contributions, and the need to provide incentives for people to pay money into private pension schemes. This is part of a much wider debate and is not covered in this study. In some countries – Spain and France, for example – there is also concern to make savings accounts available to facilitate house purchase by people on low incomes. 5 1.1.3 Credit exclusion Access to credit is important as it provides a means to smooth consumption, can protect against income shocks and, in some cases, allows individuals to make productive investments which can lead to higher future income. In addition to loans, credit facilities such as overdrafts and credit cards are of increasing importance in most developed economies1. The term ‘credit excluded’ is generally used to refer to people who cannot gain access to unsecured credit from mainstream (also known as prime or status) lenders. This can arise from their personal and economic circumstances, or a history of bad debt (Nieri, 2006, World Bank, 2005). This definition is rather more difficult to apply in countries such as the UK, where there is no interest rate ceiling and a widespread and rapidly developing sub-prime credit market which caters for people who have impaired credit histories or who are considered a high risk for other reasons. In such circumstances the debate focuses more on access to affordable credit, with people being considered credit excluded if they have to pay charges that are considerably in excess of those in the mainstream credit market (Kempson et al, 2000; Kempson et al, 2003). It should be noted that credit exclusion is much more difficult to quantify than banking exclusion, since a much higher proportion of people choose not to use credit even though they could gain access to it. This applies particularly to revolving credit facilities (overdrafts and credit cards) which people hold and choose not to use. In addition a high proportion of credit card balances are settled in full each month and are therefore not used for extended credit. However, by assessing the facilities people have, regardless of whether they are used or not, we can get an approximation of levels of access. 1.1.4 Insurance The concept of insurance exclusion is quite new and unknown in most countries – the exception being the UK, where early research has looked at exclusion from home contents insurance (Whyley et al, 1995; Kempson, 1999). There is also current policy interest in this area from both the UK Financial Inclusion Taskforce and the Treasury Committee Inquiry into Financial Inclusion. However the “financialisation of social relations in modern societies” (Gloukoviezoff, 2006) and the increasing need for individuals to assume responsibility for managing risks of various kinds leads to an increasing need for insurance products. In some cases, such as the use of motor vehicles, insurance is compulsory across all European countries, while insuring the contents of ones home is the responsibility of the individual. Similarly, life insurance is an individual responsibility. And when renting a home in France, it is 1 We have, however, excluded access to mortgages from the terms of reference of this study as it raises a much wider set of issues about access to home ownership. Finance for business purposes has also been excluded as this has been studied extensively in other European Commission studies (see for example, Siewertsen et al, 2005) 6 also very common for tenants to be required to take out insurance. Moreover, it is generally cheaper to buy insurance direct, but this is not available to people who lack access to bank payment card (either debit or credit card) and to the Internet. There is, however no clear definition of which types of insurance are considered essential so that anyone who lacks them might be considered financially excluded. The UK Financial Inclusion Taskforce is beginning to address this issue and the Association of British Insurers has commissioned (as yet unpublished) research to inform their discussions. It has, therefore, been decided not to include insurance within this project although the debates in the UK should be monitored with a view to exploring insurance exclusion across Europe at a later date. 1.2 Access or usage? There is an important distinction to be drawn between access and usage. So, in the context of banking we need to consider how to categorise people who do have transaction banking facilities with an account but choose not to use them. As we note above, such people are often considered to be marginally banked (Anderloni and Carluccio, 2006; BMRB, 2006; Barr, 2004; Corr, 2006; Kempson, 2006). Then there is the issue of people who could gain access to specific services but choose not to do so. This applies especially to consumer credit and insurance, but is also a feature of access to insurance and banking too. Here an important distinction is often made between those who choose freely not to use a particular service (such as people who have a fundamental objection to using credit) and those who are deterred from doing so because features of the products or services make them inappropriate in certain circumstances or the cost puts them beyond the reach of some people. We return to this point in section 4.1. 1.3 Are there degrees of financial exclusion? Here there are two aspects to be considered. First, as we discussed in section 1.2, people may have varying levels of engagement with banking services. So they may have a deposit account but not a transaction one. They may have access to some, but not all the transaction banking facilities that would be appropriate to their circumstances. It is for this reason, that the terms unbanked, marginally (or under-) banked and fully-banked have been coined (Anderloni and Carluccio, 2006; BMRB, 2006; Barr, 2004; Corr, 2006; Kempson, 2006). There is, however, another important dimension to this debate which is the extent to which people have access to transaction banking services but not through mainstream providers – in this case the banks and other similar organisations. In some countries 7 there are a range of alternative providers or fringe banks that cater to the needs of people without a transaction bank account. These include organisations specialising in offering cheque cashing, bill-payment or remittance services. Generally, people who use these are considered unbanked if they lack a transaction bank account or marginally banked if they have one but do not use it (Barr, 2004; Caskey, 1994; Kempson and Whyley, 1999). Likewise some people may be able to get a cash loan from a high cost sub-prime lender but not an overdraft or a credit card in the prime credit market, while others might be denied all forms of credit, even in the sub-prime market. Both are usually considered credit excluded but the term ‘completely credit excluded’ has only been used to describe the second of these two groups (Kempson and Collard, 2005). The World Bank (see Figure 1) distinguishes between those who are ‘formally served’ that is those who have access to financial services from a mainstream provider and those who are ‘financially served’ who also include people who use informal providers. In contrast to the other work described above, the term ‘financially excluded’ is only used to describe those who have no access at all (World Bank, 2005). Figure 1 Financially served Formally included Financially Excluded Bank Other formal providers Informal providers No providers Source: Concept and graphic representation from World Bank (2005) Secondly, when considering broader financial exclusion there are clearly degrees of exclusion. Therefore, research in the UK has measured not just the number of people who lack any financial products at all, but also the number of products held by those with any, categorising people into low, medium-low, average, medium-high and high levels of financial inclusion (Kempson and Whyley, 1999). 1.4 Individual, family or household exclusion? Finally, there is a debate about whether financial exclusion (and banking and credit exclusion) should be assessed at the individual or household/family level (Anderloni and 8 Caluccio, 2006; BMRB, 2006; Gluokoviezoff, 2004; Kempson and Whyley, 1999). Each has its limitations. If the assessment is made at the individual level, people appear to be financially excluded even though their partner may make extensive use of financial services and they would easily get them in their own right. This applies particularly to married women who are not in paid employment – who would not generally be considered excluded. In addition, a decision has to be made about the age range of individuals to be covered. In most countries there is a legal age limit below which credit facilities cannot be granted. As a consequence many studies have looked at adults aged 18 or over, although others cover people from the age of 16 or 15. On the other hand, assessing access at the family level (that is the head of household and their partner if they have one) we have a clearer idea of the proportion of the population with no ready access, even through a partner, but underestimate the proportion of people at risk of being financially excluded if they experienced the break-up of their family. It also underestimates the number of people who are affected. For this reason the UK Government, in its monitoring, estimates the number of adults living in family units without access to banking (Financial Inclusion Taskforce, 2006a, 2006b). Assessing access at the household level (that is considering all adults living in a household) compounds these problems still further as there is much less stability of households than of family units. Moreover, household level analysis does not provide estimates of the financial exclusion faced by young adults still living at home. 1.5 Conclusion Financial exclusion is a complex concept and consequently one that can be complicated to measure. We have, however, set out some tentative conclusions below. In our opinion people need, as a basic minimum: an account into which their income can be paid (either a transaction bank account or a deposit account of some kind); a means of making payments, including bills and remittances (that is a transaction bank account); a way of storing money for either the short or long-term (a savings account) and a means of dealing with temporary cash shortages or meeting unexpected expenses (affordable unsecured credit) (there is also a possible case for home contents insurance). Given the growth in high-cost fringe banking services that target people who do not have access to mainstream financial services, it is important to consider the interplay between services and providers when assessing the access someone has. 9 While access is the first step towards financial inclusion it is important to have information about people’s levels of usage of financial services too. As we shall see later, many people are deterred from using financial services by many of the same factors that may deny others access. It is important to acknowledge that financial exclusion is not an absolute concept (excluded or not) but a relative one, rather like poverty, with degrees of exclusion. People vary in their extent of engagement with specific services (eg transaction banking where we have both the unbanked and the marginally banked). And they also vary in the number of types of financial products to which they can gain access. It may be helpful in this context to use the term financially excluded for those who lack all products and marginally included for those who have limited access – just as poverty is often described either in terms of being in the lowest income decile or quintile or, alternatively, of being below a threshold, such as 60 per cent of median income. Finally, in measuring levels of financial exclusion, the sampling for surveys should be constructed so that the data can be analysed at both the individual and the family level. It is also important to be explicit about the lowest age covered among the individuals. When re-analysing existing data it is not always possible to ensure that all of these factors are taken into consideration. In this case it is important to be very clear about exactly what is being measured and, importantly, what is not. 10 2 Levels of financial exclusion The main source that has been used to assess levels of financial exclusion in Europe is the Eurobarometer Survey 60.2, undertaken at the end of 2003 (Anderloni and Carluccio, 2006; Nieri, 2006; Corr, 2006). To date, however, use of the Eurobarometer data has been restricted to looking at access to specific products only (banking: Anderloni and Carluccio, 2006; Corr, 2006; credit: Nieri, 2006; life insurance: Corr, 2006). We have, therefore, re-analysed the data to take this analysis further. First, it is important to describe the Eurobarometer data in more detail. It is a survey of people aged 15 or over and the 2003 data covers only those living in the EU 15 countries. In our analysis, however, we have restricted the analysis to people aged over 182. It asks about the holding of a range of financial products, including transaction accounts (with a cheque book and/or a payment card facility). It also covers deposit accounts (which pays interest but has no payment card or chequebook) and a range of other savings products, including life assurance policies, stocks/shares, collective investments (i.e. unit trusts) and bonds. The forms of credit covered include overdrafts, credit and charge cards, loans for car purchase and other purposes. This showed that, at the end of 2003, eight per cent of all adults aged 18 and over living in the EU 15 countries had no bank account at all – people we have called ‘unbanked’. A further eight per cent had only a deposit account with no payment card or cheque book – these we have called ‘marginally banked’. In other words 16 per cent had no access to transaction banking services. The same survey also asked about holdings of four types of unsecured credit: overdraft facilities, credit card facilities, loans to buy a car and loans to buy something else. Taking these four forms of credit together showed that 37 per cent of EU 15 adults had none of them at the time they were interviewed while 40 per cent had no immediate access to credit in the form of an overdraft or credit card facility. Thirdly the Eurobarometer survey asked about ownership of a range of savings products2. This showed that, at the end of 2003, 30 per cent of EU 15 adults had none of these forms of saving. On the whole, people who lacked a bank account of any kind were very likely not to have either a savings account (88 per cent) or unsecured credit (84 per cent) (Table 1). Putting this together we find that six per cent of all adults in the EU 15 had none of these three types of financial product and might, consequently, be considered ‘financially excluded’ 2 As this is the legal age of access to some types of product (including a transaction bank account with an overdraft and unsecured credit), this seems to be the most appropriate lower age to use. 11 Table 1 Percentage of the EU 15 Population excluded from credit and savings by banking status No credit All No transaction bank account Deposit account only4 No bank account at all No savings 37 81 73 3 88 30 42 0 84 All 16 8 8 Cell percentages3 Weighted base 15,526 2,560 1,266 1,293 Source: Eurobarometer 60.2 Base: all adults aged 18 or over 2.1 Levels of financial exclusion across the EU 15 countries Levels of financial exclusion varied widely even across the EU 15 countries, ranging from 1 per cent or less in Denmark, Belgium, Luxembourg, the Netherlands and Sweden, to 10 per cent or more in Italy (15 per cent), Portugal (17 per cent) and Greece (24 per cent) (Table 2, column 5). Indeed, as we shall see in subsequent sections, these countries feature among those with the highest proportions of people excluded from each of the three types of financial services we have studied in detail: banking, unsecured credit and savings. Moreover, this finding is consistent with earlier research which showed a correlation between banking exclusion and the Gini coefficient for a country (Kempson, 2006). In the UK two national studies have sought to measure levels of overall financial exclusion, using data from the annual Family Resources Survey which collects information on the ownership of bank accounts of various kinds, as well as other savings products5 and various forms of insurance. Analysis of this data identified seven per cent of households in Britain lacking any mainstream financial products at all (very similar to the five per cent identified using the Eurobarometer data). A further 19 per cent were on the margins of financial services, having only one or two products (usually these were a deposit account or a transaction banking account) (Kempson and Whyley, 1999; Meadows, 2000). Although the data are publicly available, this analysis has not been repeated for more recent years. 3 All figures are expressed as cell percentages, e.g. 76 per cent of people with a deposit account only have no form of credit 4 Some of the people listed as having a current account, actually stated that they had either a deposit or no bank account, but also said they had access to a chequebook and an overdraft facility. It was found that these people shared similar characteristics to people who stated they held current accounts, so for this reason it was felt that they were likely to be people with current accounts, but had misunderstood the question. Hence, we recoded them as holding a current account for the purposes of this research 5 Savings products included a deposit account which pays interest but has no payment card or chequebook, life assurance policy, stocks/shares, collective investments (i.e. unit trusts) and bonds 12 Table 2 Levels of financial exclusion in individual EU 15 countries Cell percentages6 No transaction bank account No credit No savings Financially excluded Un-weighted base Weighted base All 16 37 30 6 15,453 15,526 Belgium Denmark Germany Greece Italy Spain France Ireland UK Luxembourg Netherlands Portugal Finland Sweden Austria 4 9 6 76 26 41 3 39 14 6 1 19 17 16 17 33 14 42 72 52 43 13 41 27 17 20 69 40 28 33 13 15 21 41 50 25 39 21 22 28 28 62 34 7 11 1 1 2 24 15 5 1 8 5 0 0 17 2 1 2 988 970 2,000 964 955 959 957 949 1,294 574 978 947 960 969 989 421 214 3,517 435 2,408 1,660 2,327 145 2,424 18 644 413 206 356 339 Source: Eurobarometer 60.2 Base: All adults aged 18 or over In Italy the biennial panel survey on Household Income and Wealth collects data on deposit accounts (with a bank or the Post Office), other kind of financial assets (savings), life insurances and private supplementary pensions plans. In Spain the Survey on Household finances (EFF) collects data on bank accounts (including transaction accounts that offer payment facilities, deposit accounts without payment facilities and house-purchase saving accounts), other savings products, including pension schemes and unit-linked or mixed life insurance. 2.2 Levels of transaction banking exclusion across the EU 15 countries Again the Eurobarometer analysis shows wide variation in exclusion from transaction banking services across the EU 15 countries – ranging from one per cent of individuals in the Netherlands to 76 per cent in Greece (Table 2, column 2). Other countries with high proportions of individuals without a transaction account are Spain (41 per cent), Ireland (39 per cent), Italy (26 per cent) and Portugal (19 per cent). 6 All figures are expressed as cell percentages, e.g. six per cent of people in Belgium do not have a transaction bank account 13 It should be noted, however, that in Greece, Spain and Ireland, a high proportion of individuals had a deposit account even though they lacked a transaction account, so the proportion lacking an account of any kind was a good deal lower. Even so, the proportion of individuals who were completely unbanked ranged from well under one per cent in the Netherlands to 34 per cent in Greece. Again, the proportions were relatively high in Ireland (17 per cent), Portugal (17 per cent) and Italy (18 per cent). In addition to the Eurobarometer surveys, national surveys have also been undertaken in a number of member states. These are summarised below and, generally speaking, they indicate levels of banking exclusion that are somewhat lower than is found using the Eurobarometer data. This may well have arisen because of the problems of defining the different types of account in a way that can be applied across Europe. For example, the people surveyed may have under-reported accounts held with the post office, savings banks or credit unions. 2.2.1 Ireland A recent report from the Combat Poverty Agency provides additional information on the extent of banking exclusion in Ireland (Combat Poverty Agency, 2006). This shows how measures can vary widely depending on the definitions used. Drawing on data from the 1999/2000 Irish Household Budget Survey, they found that 33 per cent of households lacked a transaction bank account. While market research undertaken for the Irish Bankers Federation in 2003 showed that 28 per cent of individuals lacked such an account (Corr, 2006). These figures are somewhat lower than those from our re-analysis of the Eurobarometer data, which identifies 39 per cent of Irish individuals as lacking a transaction account in 2003. This is almost certainly because credit union usage is high in Ireland and may not have been consistently identified by the Eurobarometer survey. Taking a narrower definition of the unbanked, the Financial Regulator Consumer Survey, in 2003, found that 10 per cent of individuals aged 15 or over lacked a bank account of any kind (Corr, 2006) – very similar to the level (11 per cent) in a survey for the Irish Payment Services Organisation in 2006 (Marketing Partners Ireland Ltd, 2006). Again these are a good deal lower than the 17 per cent of individuals who were found to lack an account of any kind in the Eurobarometer survey – again due to credit union usage. 2.2.2 Italy In Italy, Banca d’Italia has commissioned a series of surveys to look at the extent of access to the Italian banking system (Banca d’Italia 2002, 2004, and 2006). The most recent survey, in 2005, found that 14 per cent of breadwinners in Italy lacked a bank account of any kind (Banca d’Italia 2006). Once again this is slightly lower than the 18 14 per cent of individuals lacking a bank account in the Eurobarometer data. It does, however, need to be remembered that the population being surveyed differs in the two studies. 2.2.3 Spain Although the Eurobarometer survey shows that 41 per cent of individuals in Spain lacked a transaction account, 10 per cent lacked an account of any kind. Both figures are considerably higher than those identified in a panel survey commissioned by the Banco de Espana which found that 17 per cent of households lacked an account with payment facilities, while only two per cent had no account at all (Banco de Espana, 2005). As in Italy, it is important to remember that the population being surveyed in the two studies differs. 2.2.4 United Kingdom In the UK, analysis of the Family Resources Survey data shows that 12 per cent of households and 14 per cent of individuals lacked a current account in the 2002/03 survey. In this case the figures for individuals were similar to those found in the Eurobarometer data (15 per cent). Since then the Government’s Financial Inclusion Taskforce has commissioned a series of Omnibus surveys between May 2005 and June 2006 to monitor progress towards the goal (shared by Government and the banking sector) to halve the numbers of individuals living in households without a transaction bank account7 and the numbers with no bank account at all. Aggregated data from these surveys show that in 2005/06 the number of families without a current account had fallen to 2.21 million (compared with 3 million in 2002/03); while the number with no bank account of any kind fell to 1.5 million (from 2.9 million in 2002/03) (Financial Inclusion Taskforce, 2006a. 2006b). There were falls of a similar size in the numbers of individuals living in families either without a current account or with no account of any kind. Please note, we will be able to insert percentages from the 2005/06 FRS data when it is available in a month or so. The Financial Inclusion Taskforce has also commissioned a survey that was designed to explore the extent and nature of banking more fully. This included levels of use of accounts by account-holders and also the overlap between banking exclusion and the use of various forms of unsecured credit (BMRB, 2006). This found that eight per cent of individuals lacked a transaction bank account in their own name, while five per cent of individuals did not have such an account themselves nor did they live with a partner who 7 From 2003, basic bank accounts (simple transaction accounts that cannot become overdrawn) became more common, and the Post Office has offered a stored value card (The Post Office Card Account). The way that information about these was collected on the Family Resources Survey in 2003/03 and 2004/05 means that the data cannot be used to measure levels of account-holding accurately. 15 had one. They also identified that seven per cent of households either lacked a transaction account or had one but did not use the transaction banking facilities. 2.3 Levels of credit exclusion across the EU 15 countries Using the Eurobarometer data it is possible to compute two variables to measure the level of exclusion from unsecured credit. The first is the proportion of people with no credit in the form of an overdraft, credit card or loan; the second is a narrower definition - of access to mainstream revolving credit facilities (overdrafts and credit cards). Both measures, however, tend to provide an over-estimate as they will include people who are opposed to borrowing and so decline such facilities8. Importantly, the extent of this will vary from country to country, depending on the prevailing attitude towards borrowing. It should also be noted that there are three quite distinct types of credit card in Europe, and also that the Eurobarometer survey puts charge cards together with credit cards even though they do not offer extended credit. Secondly, the Eurobarometer survey excludes some forms of credit that are quite prevalent in some countries – including goods bought on credit through mail order catalogues and, in the UK and Ireland, a form of credit known as hire purchase. Finally, experience of designing surveys in the UK has identified that a significant proportion of consumers confuse debit cards with credit cards. Despite these concerns about the Eurobarometer data, it does offer at least some insight into levels of access to credit across the EU 15 countries. These should, however, be kept in mind when interpreting the findings of the analysis. As we reported above, across the EU 15 countries almost four in ten (37 per cent) of adults aged 18 or over did not have any credit facilities in 2003, and 40 per cent had neither an overdraft nor a credit card. The proportion of people with no form of credit was lowest in France (13 per cent), Denmark (14 per cent), Luxembourg (17 per cent) and. The highest proportions were found in Greece (72 per cent) and Portugal (69 per cent), followed by Italy (52 per cent), Spain (43 per cent) and Germany (42 per cent). On the more limited definition, four in ten (40 per cent) of adults in EU 15 countries had neither an overdraft nor a credit card facility and the variations across the 15 countries showed the same pattern as was reported above. So access was least restricted in France (14 per cent), Denmark (18 per cent) and Luxembourg (18 per cent), but most limited in Greece (76 per cent) and Portugal (75 per cent). In Great Britain, a survey undertaken for the Government found that, in 2002, 26 per cent of households had no credit facilities9 (Kempson, 2002). This is consistent with the Eurobarometer data which shows that 30 per cent of British adults had no credit facilities. However, other UK research, using a longitudinal data set where the same people are reinterviewed each year, has shown that snapshot surveys lead to over-estimates of the 8 Research in the UK, for example, showed that eight per cent of households did not have any form of credit because they were opposed to borrowing. 9 This includes credit cards and overdrafts on which no money was owed and is, therefore, similar to the Eurobarometer definition except that it does include people who have access to credit in the sub-prime market only. 16 numbers of people who are not using credit. Although 64 per cent of adults did not owe money on unsecured credit in 2000 a much smaller proportion of people (45 per cent of all adults) had not owed any money in either 1995 or 2000 (Kempson et al, 2004). Where more direct measures of credit exclusion have been attempted at a national level, they show that the figures from the Eurobarometer do seem to greatly over-state the proportion of people excluded from the mainstream credit market – for the various reasons spelt out above. The UK National Consumer Council has, for example, estimated that 7.8 million people (17.5 per cent of the adult population aged over 18) had applied for credit and been refused several times and could therefore be considered excluded from mainstream credit (Treasury Select Committee 2006a). This is considerably lower than the 27 per cent of the UK population that the Eurobarometer data indicates as having no credit facilities A survey carried out in 2005 in France, Spain and Italy has attempted to understand the behaviour of people on low incomes (unemployed or employed on a temporary basis) with regard to credit access (Nieri, 2006). Although the aim of the research was not to measure the level of credit exclusion but to analyse qualitative aspects, it showed that a large proportion of people on low incomes did have access to credit, although not necessarily from a bank. Most of them, however, paid no attention to the difference in costs and terms between banks and other financial institutions and were not able to evaluate how high the costs were. About half of the people interviewed had never approached a bank or a credit institution for a loan: this percentage was higher still for migrants (62 per cent of the sample), especially those living in France. However, only 16 per cent of respondents said that they had applications for loans rejected – a level that is remarkably similar to that found in the UK. Adding to these the people who said they did not apply because they expected to be rejected (21 per cent) gives a figure of 37 per cent of people who needed credit but were excluded or chose to self-exclude (Nieri, 2006). The Eurobarometer data, which looks at the whole population, not just those on low incomes, indicates that levels of credit exclusion were 13 per cent in France; 43 per cent in Spain and 52 per cent in Italy. In other words, by using the Eurobarometer data to assess the numbers of people who do not have any credit facilities we are almost certainly adopting a wide definition of credit exclusion – including those who self-exclude through choice as well as those with constrained access. 2.4 Savings across the EU 15 countries As we saw earlier, around a third (30 per cent) of adults living in one of the EU 15 countries had no savings account at the time of the 2003 Eurobarometer survey. Once again there were wide variations across individual countries. Sweden was the country with the highest incidence of savings account-holding – only seven per cent of adults lacked a savings account. At the other extreme, countries where a large proportion of the population did not have a savings account included Portugal (62 per cent), Italy (50 per cent), Greece (41 per cent) and France (39 per cent). 17 Analysis of the Family Resources Survey in the UK suggests that just over a quarter (27%) of households (Department for Work and Pensions, 2006) and over a third (37 per cent) of individuals (Rowlingson et al, 1999) lacked any savings. This last figure is rather more than the proportion indicated by the Eurobarometer survey (23 per cent). Analysis of the Household Income and Wealth survey in Italy shows that 14 per cent of households lack any savings, i.e. they have no assets at all, while 64 per cent only have an account that is used for transaction purposes, and not for savings. 2.5 Conclusion Only a minority of the adult population living in the EU 15 countries is affected by financial exclusion – two in ten lack access to transaction banking facilities; around three in ten have no savings and four in ten have no credit facilities, although rather fewer (less than one in ten) report having been refused credit. The proportion of people lacking access to any of these three forms of financial service is lower still – at around six per cent of the adult population aged 18 or over. There are, however, considerable variations in levels of financial exclusion even across the EU 15 countries. In general, levels are lowest in the countries such as Netherlands, Denmark, Sweden and Luxembourg where the standard of living is universally high. They are highest in the Southern European countries such as Greece, Spain, Italy and Portugal. It should be noted that there is very little data on levels of financial exclusion across Europe. Most reports have relied to some degree on published data from the Eurobarometer survey, which in 2003 covered only the EU 15 countries. The small number of countries where any separate measurement has been attempted have used either national household budget surveys or ad hoc surveys to do so. Comparing the results of these with those obtained from our own analysis of the Eurobarometer data reveals some discrepancies, particularly in relation to transaction banking in countries like Spain, Portugal and Italy where savings banks or the post office play an important role. The same is true to some degree in Ireland where credit unions are prevalent. In any future surveys covering all or a number of EU countries, it will be important to ensure that the wording of questions for banking is tested to ensure that it reflects local service provision. 18 3 Who is most likely to be financially excluded? Previous research in the UK has shown that complete financial exclusion among households has very strong links to low income (Kempson and Whyley, 1999; Meadows, 2000). It was, therefore, most common among people who were not in paid work and in households where there was no wage earner. Consequently unemployed people, lone parents and people unable to work through disability had above average levels of exclusion. There was also a link with age, with the youngest and oldest people being most likely to be excluded, and a link with educational attainment so that the more education someone had received the less likely they were to be excluded (Kempson and Whyley, 1999; Meadows, 2000). Financial exclusion was also very prevalent among ethnic minorities and migrants (Atkinson, 2006; Kempson and Whyley, 1999; Meadows, 2000). In addition to these personal characteristics, statistical analysis has also shown that living in a neighbourhood that had high levels of deprivation increased the likelihood of being financially excluded still further (Kempson and Whyley, 1999) and so too did having friends and family who were financially excluded (Meadows, 2000). Other research has looked largely at the types of people who lack access to transaction banking (Anderloni, 2003; Anderloni and Carluccio, 2006; BMRB, 2006; Barr, 2004; Bayot, 2005; Corr, 2006; Devlin, 2005; Gloukoviezoff, 2005; Kempson, 2006; Kempson and Whyley, 1998; IFF, 2000; Test Achats, 2001). On the whole, the findings mirror those in the studies of financial exclusion just described. One study has explored gender differences in transaction account-holding and found that ethnicity, having children, personal income and economic activity status all had a greater effect on women’s propensity to be financially excluded than they did on men. This is consistent with qualitative research showing that some married women give up having an account in their own name when they give up work to have children (Kempson and Whyley, 1998). Analysis of the Eurobarometer data is consistent with this earlier research (Table 3). This shows that women were almost twice as likely to be completely financially excluded as men and had a higher incidence of exclusion from all kinds of financial services. Young people (aged 18-25) included the largest proportion who were financially excluded generally and a very high level of exclusion from all forms of financial services. Overall financial exclusion was high among the oldest people (aged 65 and over) as well; they also had high levels of banking and credit exclusion, but were more likely than average to have savings. 19 Table 3 Types of people likely to be financially excluded in the EU 15 countries Cell percentages No transaction bank account All Family type Single parent Couple with children Single no children Couple no children Respondent work status Self employed Employed Looking after home Student Unemployed Retired/unable to work Head of household work status Self employed Employed Looking after home Student Unemployed Retired/unable to work Age left education Up to 15 16-19 20 + Still studying Gender Male Female Age 18-25 26-44 45-64 65 + Geographical area Rural area or village Small or middle sized town Large town Income quartile Lowest Second lowest Second highest Highest No credit No savings Financially excluded Weighted base 17 37 30 6 15,526 22 11 20 15 40 22 46 36 43 25 38 24 9 3 7 5 848 3,619 5,362 5,545 11 10 27 30 24 20 22 23 48 56 51 52 23 26 38 51 45 27 3 2 11 15 10 6 1,270 6,644 1,804 997 935 3,874 16 13 26 8 22 22 31 27 58 35 51 53 28 29 40 40 44 30 6 4 10 2 9 7 1,810 7,995 453 328 601 4,339 28 12 8 28 55 30 21 55 33 28 23 48 9 4 2 14 4,245 6,625 3,554 1,102 15 18 33 40 28 32 4 7 7,491 8,033 24 13 13 23 47 26 32 55 47 29 25 28 11 4 4 7 2,139 5,503 4,710 3,173 18 16 16 39 37 34 29 30 31 6 6 5 4,764 6,278 4,375 21 14 10 9 50 37 30 18 41 30 24 16 8 4 3 2 2,827 2,590 2,106 2,556 Source: Eurobarometer 60.2 20 Lone parents and single people (who tended to be either quite young or quite old) included a greater proportion of people who were living with a partner, whether they had children or not. There was a strong link with level of education received and also with income. So the less well-educated people were and the lower their household income, the more likely they were to be excluded from all forms of financial services. Not surprisingly then, unemployed people, and people looking after the home full-time (including both lone parents and wives) had high levels of financial exclusion and were very likely to be excluded from transaction banking credit and savings. So, too were people living in households where the head of household was either unemployed or looking after a family full-time. Interestingly, people who described themselves as retired or unable to work through disability10 had high levels of apparent credit exclusion, and slightly higher than average levels of exclusion from transaction banking. They did, however, have average levels of engagement with savings products and also of exclusion from all forms of financial services. Finally, although a great deal has been written about the difficulties accessing financial services faced by people living in a ‘rural area or village’, levels of financial exclusion were very similar to those found among people living in a ‘small or middle sized town’ or a ‘large town’ (which presumably includes cities). 3.1 Variations in the types of people who are financially excluded across EU 15 countries It is interesting to analyse whether the same types of people are financially excluded in countries with high levels of financial exclusion as are found in those where the levels are low, or whether a lower incidence of financial exclusion means that it tends to be even more concentrated among certain groups in society. To undertake this analysis we have concentrated on people who lacked any of the three types of financial services, and we have grouped countries to give us sufficient numbers for analysis. In doing this we have looked at three groups: countries with below-average levels of financial exclusion; those with average levels and, finally, countries with high levels of financial exclusion. 10 The Eurobarometer data does not distinguish between these two groups. We could, however use the age variable to disaggregate, but will do this later. 21 Table 4 Types of people likely to be financially excluded by whether live in a country with high, average or below average level of financial exclusion % All High11 Base14 Cell percentages Level of financial exclusion Average12 Low13 All % Base % Base % Base 16 2,866 5 3,202 1 9,385 6 15,453 201 9 21 15 83* 608 1,009 1,159 15 4 7 3 223 883 1,039 1,016 2 1 2 1 531 2,183 3,080 3,468 9 3 7 5 837 3,674 5,128 5,643 8 7 28 36 31 18 397 966 373 221 166 743 1 2 10 11 15 5 265 1,452 546 216 149 574 1 1 3 3 2 2 628 4,194 812 598 668 2,485 3 2 11 15 10 6 1,290 6,612 1,731 1,035 983 3,802 13 14 ~ ~ 18 20 618 1,205 ~ ~ 56* 942 4 4 20 0 27 5 429 1,825 129 57* 93* 669 1 1 1 0 2 2 792 4,986 259 309 499 2,540 6 4 10 2 9 7 1,839 8,016 428 371 648 4,151 23 11 5 36 1,333 776 536 221 6 5 1 11 867 1,629 481 225 2 2 1 2 1,828 3,785 3,077 695 9 4 2 14 4,028 6,190 4,094 1,141 13 20 1,372 1,494 5 5 1,531 1,671 1 2 4,510 4,875 4 7 7,413 8,040 32 11 11 24 442 979 840 605 11 5 3 4 532 1,176 908 586 2 1 1 2 1,239 3,347 2,976 1,823 11 4 4 7 2,213 5,502 4,724 3,014 19 16 15 935 1,048 871 6 5 4 930 1,111 1,140 1 2 2 3,164 3,739 2,369 6 6 5 5,029 5,898 4,380 8 5 1 1 379 532 291 441 3 1 0 1 1,861 1,834 1,590 1,790 8 4 3 2 2,733 2,802 2,293 2,572 Family type: Lone parent Couple with children Single no children Couple no children Respondent work status: Self employed Employed Looking after home Student Unemployed Retired/unable to work Head of household work status: Self employed Employed Looking after home Student Unemployed Retired/unable to work Age left education: Up to 15 16-19 20 + Still studying Gender: Male Female Age: 18-25 26-44 45-64 65 + Geographical area: Rural area or village Small or middle sized town Large town Income quartile: Lowest 31 493 Second lowest 12 436 Second highest 13 412 Highest 7 341 Source: Eurobarometer 60.2 Base: All adults aged 18 or over 11 Greece, Italy and Portugal, which had levels of exclusion of above 15 per cent Spain, Ireland and the UK and exhibited levels of exclusion of between two and eight per cent 13 Belgium, Denmark, Germany, France, Luxembourg, Netherlands, Finland, Sweden and Austria. Typically, they had levels of exclusion of below two per cent 14 All base figures are un-weighted * These percentages should be used with caution owing to the small bases. ~ Numbers too small for analysis. 12 22 On the whole, the same types of people had an above-average likelihood of being financially excluded regardless of whether they lived in an EU 15 country with a high or average level of financial exclusion (Table 4). The exceptions were women and older people (aged 65 or over) who only really had an enhanced risk of financial exclusion in countries where the prevailing rate was high. In general, the likelihood of exclusion was considerably lower for all groups of people in countries with average levels of financial exclusion nationally than it was for their peers living in countries with high levels. The likelihood fell still further among people living in the nine countries where financial exclusion was very low, so that no group of people really stood out as being especially affected. Taken together, this suggests that where countries have been successful at reducing the numbers excluded from financial services all groups in society benefit, with none getting seriously left behind. We also plan to run regression analysis, and explore the role that attitudes play (using factor analysis), but later in the project. 23 4 The causes and consequences of financial exclusion The earliest analysis of financial exclusion concluded that it involves “those processes that serve to prevent certain social groups and individuals from gaining access to the financial system” (Leyshon and Thrift, 1995). The authors contend that people with limited incomes and certain disadvantaged social groups represent too high a risk as customers for mainstream financial institutions, which then avoid geographical areas where these groups of the population live. In other words, financial exclusion was seen in terms of physical and geographical access. Since then there has been a large body of research that has identified a wide range of other factors that restrict access to and use of financial services. A range of societal factors have been identified as having an impact on people’s access to and use of financial services. These include liberalisation of financial services markets, which has, in turn, led to an increase in the number and complexity of financial products and providers. While this has widened access, the confusion that arises makes it difficult for some people to engage with financial services (Anderloni and Carluccio, 2006; Atkinson et al, 2006; Kempson et al, 2000). Secondly, there are structural changes in labour markets, leading to greater ‘flexibility’ and growing job insecurity, which in some countries is accompanied by high levels of youth unemployment (Anderloni and Carluccio, 2006). Thirdly, tightening of money laundering rules in response to terrorist attacks means that many people face difficulty getting access to services (Anderloni and Carluccio, 2006; Kempson, 2000). Fourthly, social assistance programmes can play an important role – with both the level of payments and the method by which they are made having an effect on levels of financial exclusion. And for benefit receipt the rules may deter people from saving where that might reduce the level of assistance they would qualify for (Anderloni and Carluccio, 2006; Citizens Advice; 2006; Kempson and Whyley, 1999). Fifthly, financial exclusion is affected by demographic changes such as rising levels of divorce and the tendency for young people to leave home at an older age (Anderloni and Carluccio, 2006; Kempson et al, 2000). Finally, as reported in section 2, there is a link between levels of banking exclusion and levels of income inequality as measured by Gini coefficients (Kempson, 2006). Much of the previous research and analysis has, however, tended to concentrate on the reasons for exclusion in specific areas of financial services. In the area of transaction banking a range of factors covering both supply and demand has been identified across a wide range of countries (for an overview see: Anderloni and Carluccio, 2006; Corr, 2006; Kempson, 2006). On the supply side, banks refuse to open full transaction bank accounts for certain groups of people, such as those with a poor credit history, unstable patterns of employment or those who fail credit scoring systems because their characteristics mean they are assessed as a high risk. People unable to satisfy identity requirements also find it difficult to open an account. This applies especially to migrants but can also affect a wider group of people who do not have the standard forms of identity required. This is a particular problem in countries that lack identity cards, where banks rely on passports and driving licences instead. 24 On the demand side, the terms and conditions and charges associated with transaction bank accounts deter both access and use. This includes such things as minimum balances, monthly charges and charges per transaction – especially if the charges are regressive and disproportionately affect people on low incomes. People are also deterred from accessing and using transaction banking services for a range of psychological and cultural reasons. These include elderly people who are part of a ‘cash only’ generation, migrants and also people on low incomes generally, who frequently see banking as only being appropriate for people who are better off than they are and fear losing control of their money if they cease to deal only in cash. In Italy, people are deterred from opening an account if it does not have an overdraft facility to ease access to money paid in. Delays in clearing cheques paid into an account mean that people cannot have instant access to any money paid in (Anderloni, 2003). The balance of importance of these factors does, however, vary between countries. In Italy, for example, transaction bank charges are very high (Anderloni and Carluccio, 2006). In the UK there are no transaction charges but proof of identity is a particular problem along with very high charges for unauthorised overdrawing of accounts (Collard et al, 2001; Kempson and Whyley 1998; Kempson, 2006). While in France many people are denied access to an account as a result of over-indebtedness (Gallou and Le Queau, 1999; Kempson, 2006). In Sweden, which has traditionally had high levels of banking inclusion, the general move to internet-based banking is denying use of transaction accounts to those who lack access to the internet (Anderloni and Carluccio, 2006). This last point is important because it underlines the need to constantly reassess barriers to access and use. Moving on to consumer credit, previous research has identified a range of similar factors – again relating to both supply and demand. Refusal by credit companies is a very significant reason across all countries, as a result of lack of information about an individual at credit reference bureaux, an adverse credit history or failing the score card operated by creditors as a consequence of lack of stable employment, low income and other personal characteristics (Corr, 2006; Ellison, Collard and Forster, 2006; Kempson and Whyley, 1999; Kempson et al, 2000; Nieri, 2006). Often just as significant is the fact that some people do not apply for credit as they think they will be turned down. (Nieri, 2006; Kempson and Whyley, 1999; Kempson et al, 2000). It has been estimated that across France, Italy and Spain, 16 per cent of people have actually been refused credit and another six per cent did not apply because they expected to be refused (Nieri, 2006). Also significant in limiting access to and use of unsecured credit is a fear of borrowing – and especially of using forms of credit such as overdrafts and credit cards where it is easy to lose control over spending (Kempson and Whyley, 1999; Kempson et al, 2000; Collard and Kempson, 2005). People who cannot easily gain access to unsecured credit are often deterred by the high cost and poor contractual terms obtained through intermediaries (Nieri, 2006) or in the sub-prime market (Collard and Kempson, 2005). Many people on low incomes need to borrow fairly small sums of money for a short period of time. They also prefer fixed term loans which they know they will repay. Most mainstream lenders have minimum amounts that they are prepared to lend as a fixed term loan which are way 25 in excess of the requirements of such people (Carbo et al, 2005; Collard and Kempson, 2005; Corr, 2006). Finally, religion can act as a barrier to use – especially in Muslim populations (Collard et al, 2001; Collard and Kempson, 2005; Kempson et al, 2000) In contrast to transaction banking and unsecured credit, there has been rather less investigation of the reasons why people lack savings accounts. Research in the UK has, however, shown that the explanation is not as simple as people not having sufficient money to save. Many people on low incomes do save but do so outside formal savings organisations, mainly in cash at home or through informal savings and loans schemes (Kempson, 1999). There are a number of explanations for this. First, some people face the same difficulties providing proof of identity as we have noted for transaction bank accounts. Secondly, as we have seen above, clearing times for cheques deter people in Italy from opening accounts that do not allow instant access to the funds deposited (Anderloni, 2003). But, perhaps, more significantly, people do not put their savings into an account with a bank or other similar organisation because they believe that a large minimum deposit is required or they feel that using such institutions is inappropriate if they have only small sums of money to save. Informal savings schemes are more accessible psychologically (Collard, 2001; Corr, 2006; Kempson, 1999; OLR, 2006). The number and complexity of savings products also acts as a deterrent (Citizens Advice, 2006). Finally, religious factors deter people from opening savings accounts just as they deter them from using credit (Collard et al, 2001; Kempson 1999). 4.1 An overview of the causes of financial exclusion A number of commentators have attempted to pull together the various factors affecting access to and use of financial services. The earliest of these was in 1999 which identified six key factors (Kempson et al 2000): Access exclusion: the restriction of access through the processes of risk assessment; Geographical exclusion: lack of access to branches of banks and savings institutions and to cash machines. Condition exclusion: where the conditions attached to financial products make them inappropriate for the needs of some people; Price exclusion: where some people can only gain access to financial products at prices they cannot afford; Marketing exclusion: whereby some people are effectively excluded by targeting marketing and sales; Self-exclusion: people may decide that there is little point applying for a financial product because they believe they would be refused. Sometimes this is a result of having been refused personally in the past, sometimes because they know someone else who has been refused, or because of a belief that “they don’t accept people who live round here. 26 The authors note that the relative importance of these factors varies between different types of product. So, for example, access exclusion and self-exclusion are especially important in determining use of consumer credit; while condition and price exclusion are much more important with regard to banking and insurance. They also point out that these various barriers lead to difficulties in both accessing financial services and using them. As a concrete example, many people on low incomes do have a transaction bank account but choose not to use it because they cannot afford the charges to do so. This analysis has been used and developed by a number of subsequent authors (see for example, Anderloni, 2003; Anderloni and Carluccio, 2006; Beck and de la Torre, 2006; Carbo et al, 2004; Devlin, 2005; Gloukoviezoff, 2005; Honohan, 200515) and has gradually been refined. Speaking at a World Bank conference in 2006, Kempson, re-grouped the factors restricting access to financial services, separating supply and demand side factors as follows: Supply factors • Refusal by financial service companies • Identity requirements • Terms and conditions • Charges • Physical access problems Demand factors • Income considered too low • Fear of loss of control • Psychological barriers • Cultural barriers • Religious barriers While Gloukoviezoff (2005) has suggested the following schema, which has been used and adapted slightly by others (Anderloni and Carluccio, 2006). This subdivides the supply and demand side factors into those creating difficulties of access and those creating difficulties of use. 15 Beck and de la Torre (2006) have identified three groups of barriers: ‘geographic limitations’; ‘socioeconomic limitations’, where access is denied to certain socio-economic groups through price, conditions, discrimination or limited financial capability and ‘opportunity limitations’ where people are denied access because they lack collateral or are not well connected. Honohan (2005), in contrast, proposes the following three categories: ‘price barrier’ , ‘information barrier’ when a household’s credit worthiness cannot be established and ‘product and service design’ when financial service providers fail to offer services that meet the needs of people on low incomes. 27 Table 5 Difficulty of access versus difficulty of use Difficulty of Access Supply side factors Direct screening - Indirect screening - Demand side factors Self-exclusion - Customer profile scored “too costly to serve” - Company policy to decline to serve some customers (Access exclusion) Company policy to close/ not offer services in unprofitable areas (i.e. branch closures, failure to provide cash machines in deprived areas) (Geographical access exclusion) No marketing to less profitable/ market segments (Marketing exclusion) Consumers give up/refuse to use some services (Selfexclusion) Difficulty of use Supply side factors - Customer profile scored “too risky to serve” - - Demand side practices Eschew banking relationship - Companies force a wider usage of services (policy of packaging products or link some services to others, etc.) Companies charge higher fees for those services that are more frequently used by undesired customers (Price exclusion) Company uses penalty clauses and/or charges for non payment or dishonoured cheques to discourage high risk customers (Price and condition exclusion) Companies take advantage of lack of knowledge of their rights from weak customers (undue foreclosure, dishonour of plans in case of over-indebtednesses.) Customers do not keep company informed about informed about financial difficulties Customers prefer to use alternative financial providers (eg cheque cashers, sub-prime lenders) Source: Gloukoviezoff (2005) (edited) However, none of these models of exclusion deals adequately with the complexity of the situation described briefly above. We have, therefore, developed a new schema for financial exclusion that combines ideas from each of the existing models. This is presented in the table below, which categorises the barriers into three groups: societal; supply and demand. The table also indicates whether they act to limit access or use, and also the type of financial services provision where they have their main effects. It should, however, be re-iterated, that not all these factors will necessarily apply in any one country. Moreover, the balance of their importance will also vary from country to country. It is also important to note that the reasons for financial exclusion are complex and these barriers do not often act in isolation. So any one individual may be prevented or deterred from using financial services for several, often reinforcing, reasons. 28 Table 6 Factors affecting difficulty of access or use Access or use The possible relationship* Type of service affected** Societal factors Liberalisation of markets Access (+) increased competition may result in more attention been paid to all market segments or (-) less attention to marginal market segments (-) levelling the regulation of different banking/financial institutions generally resulted in the disappearance of types of financial institutions which traditionally served people on low incomes Banking**, Credit; Savings Labour market changes Access Banking; Credit (-) more flexible markets mean less stable incomes and, often, less creditworthiness Money laundering rules/Identity checks Access; Use (-) preventing the use of the financial system for money laundering and financing of terrorism brings a greater bureaucracy to financial transactions Banking; Savings Fiscal policy Access; Use (-) duties and taxes on banking services may represent a heavy burden for people on low incomes people, reducing the convenience of using the services, (+) but fiscal measures can provide incentives (reducing cost or granting fiscal advantages) for financial inclusion Banking; Savings, Credit Social assistance Access; Use (-) paying social assistance in cash can deter people from opening a bank account (+) but antipoverty policies can facilitate financial inclusion Banking; Credit, Savings Demographic changes Access; Use (-) older people generally suffer more from the technological divide (+) young people have a higher propensity to use credit, but (-) their risk of over-indebtedness is higher and may lead to exclusion. Banking; Credit; Income inequalities Access (-) higher income inequalities and literacy disparity are normally associated with greater difficulties of access Supply factors Geographical access Risk assessment Price Product design (terms and conditions) Service delivery (eg internet) Complexity of choice Marketing Access Access Access; Use Access; Use Access; Use Access Access (-) / (+) (-) / (+) (-) / (+) (-) / (+) (-) / (+) (-) / (+) (-) / (+) Access Access Access Access; Use (-) (-) (-) (-) Access Access Access (-) (-) (-) Demand factors Belief that not for poor Fear of loss of financial control Mistrust of providers Concern about costs Preference for alternative providers and cultural factors Religion Opposition to use Generally, in the past, supply factors played a negative role (obstacles), recently sometimes new strategies of some innovative banks turned these factors positively in order to satisfy the specific needs of marginal segments Listed demand factors generally play a negative role. Initiatives to improve financial capability and literacy as well as actions aimed to encourage to develop confidence in the banking system may reduce their negative impact. Banking, Credit Banking; Savings Banking; Credit Banking; Credit Banking; Credit Banking; Credit; Savings Savings Banking; Credit; Savings Banking; Credit; Savings Banking; Credit Banking; Credit; Savings Banking; Credit Banking; Credit; Savings Banking; Credit; Savings Credit * (+) if the factor facilitates financial inclusion, (-) if the factor causes financial exclusion ** Note in this context ‘banking’ refers to ‘transaction banking’ 4.2 Links between financial exclusion and social exclusion The links between financial exclusion and social exclusion are complex. Financial exclusion can contribute to social exclusion – for example, not having a bank account into which wages can be paid can be a barrier to taking a job; not having access to credit can make it more difficult to be part of the wider consumer society. On the other hand, financial exclusion can be a consequence of social exclusion – through limited access to mainstream financial services in areas of high deprivation, for example. Societal, supply and demand factors can play a role in the exclusion or limited inclusion of individuals (see Table 6). So, the lack of permanent address and identification documents, the lack of an “official” or stable job, not speaking the national language, and living in deprived economic circumstances16 may render it more difficult to have easy and fair access also to basic financial services. Indeed, empirical evidence suggests that people who are unbanked persons or marginally served by mainstream financial services are more likely to belong to segments of the population who are socially excluded or only marginally included (Anderloni, 2003; Anderloni and Carluccio, 2006; Kempson and Whyley, 1999). For these reasons, previous studies have emphasised the causal link between financial exclusion and the broader phenomenon of social exclusion (Kempson and Whyley 1999; Kempson et al, 2000; McKay and Collard, 2006). Indeed, financial exclusion has been seen as a process that contributes to the development of social exclusion at both the individual and the collective level. “Where whole communities have limited access to financial products, the process becomes self-reinforcing and an important contributor to social exclusion more generally” (Kempson & Whyley, 1999). We consider the consequences of financial exclusion in more in depth below (section 4.4). 4.3 Links between financial exclusion and over-indebtedness The relationship between financial exclusion and over-indebtedness is equally complex. First, as we have seen above, people who are over-indebted or have been over-indebted in the recent past can face real difficulties getting access not only to unsecured credit but also to transaction banking facilities (Anderloni and Carluccio, 2006; Gloukoviezoff, 2005a, 2005b; Kempson, 2006). 16 An example of this is the fact that in credit scoring models, variables such as area of residence (i.e. postal code or also specific address) kind of job position, period of time in the same working place and of living at the same address are used in order to define the credit score. These models are mainly used for deciding whether to accept or to refuse a demand for unsecured loans and mortgages, but often represent a tool for customer segmentation and for identifying “undesirable” customers. Secondly, the design of bank accounts – especially where there are high penalty charges for unauthorised overdrafts and/or where payments are withheld through lack of funds in the account - can push people with temporary liquidity constraints into financial difficulty (Collard et al, 2001; Kempson and Whyley, 1999). Finally financial exclusion can lead people into over-indebtedness. Those who cannot access mainstream credit providers either turn to high-cost alternatives (intermediaries or sub-prime lenders) or, worse still, to illegal lenders that not only levy very high charges but arbitrary terms and conditions (Collard and Kempson, 2001; Corr, 2006; Ellison et al, 2006). This often causes people to fall into financial difficulty and therefore the situation risks becoming really incurable. Where this kind of provider operates at the margins of , legality, institutional remedies to redress the situation (debt advice services, special procedures for county court administration orders, debt rescheduling and debt adjustment) are often avoided17. 4.4 The consequences of financial exclusion The severity of the consequences of financial exclusion depends to a large extent on the prevailing level of financial exclusion in a country. It is, for example, more problematic to rely on cash transactions in a country where almost everyone else has a bank account than it is in one where a significant proportion of the population lack one. 4.4.1 Banking People with no bank account at all face difficulties dealing with cheques made out in their name by a third party. Often they have to pay to have the cheque cashed and in some countries there are networks of cheque cashing companies whose main purpose is to offer this service (Anderloni and Carluccio 2006; Hogarth and O’Donnell 1999, Kempson and 17 See for the UK, H.M. Treasury, Speech given by the Economic Secretary to the Treasury Ed Balls MP, to the Resolution Foundation Conference, London, March 14 th 2007 “Managing debts, like a mortgage or a credit card, is part of our every day lives. But debt can quickly become unmanageable in the event of an unexpected drop in income - especially for low-income families with little or no savings. Research has shown that almost half of debt problems are caused by a surprise event such as the loss of a job, a longterm illness or family break up. And without access to mainstream financial support or advice, and with no savings to fall back on, families can find themselves forced to use extortionate illegal loans from criminals who use violence and intimidation to extort money from the poor”. Tackling illegal loans sharks around the country in the UK is a priority and the Government ‘s 120 million Financial Inclusion Fund has been devoted to this goal too. In Italy to combat loans sharks two special funds have been created. They are aimed, respectively, to prevent people from falling into the usury trap and to help those who have already fallen to get out of those devastating conditions. The first such fund is called “Fund for the prevention of usury”. It finances special funds that actually help people at risk. The second operates in the following way: it offers banks or other credit institutions guarantees in order to permit people who, according to foundation’s constitutional rules, merit credit but are not able to obtain it on the open market. 31 Whyley, 1998; Kempson et al, 2000). It is also difficult to take employment in countries where payment of wages is by electronic transfer into a bank account (Citizens Advice, 2006; Treasury Committee, 2006b). Lacking a transaction bank account with payment facilities can make payment of bills costly – particularly when such accounts are the norm and outlets for paying in cash are closed (BMRB, 2006; Corr 2006; Kempson and Whyley, 1998; Kempson et al, 2000). Moreover, the cost of banking services bought separately is generally higher than those accessed within a stable relationship with the bank. Consequently, occasional payments of utility bills, payment of taxes, bank transfers to third persons, cashing cheques and money orders at the banking counter are more expensive for those who are not customers of the bank. Therefore there are relevant negative economic consequences of dealing occasionally with banks, not only of using alternative financial services providers. Many utility companies offer discounted rates for people paying their bills electronically each month (BMRB, 2006; Corr, 2006; Kempson and Whyley, 1998; Kempson et al, 2000). People lacking a payment card (debit or credit card) are also unable to take advantage of the lower prices of goods and services bought in this way. 4.4.2 Credit People unable to get credit from banks or other mainstream financial providers often have to use intermediaries or sub-prime lenders where the charges are higher and the terms and conditions may be inferior (Anderloni and Carluccio, 2006; Collard and Kempson, 2005; Corr, 2006; Kempson et al, 2000; Treasury Committee 2006a). 4.4.3 Savings and asset building Finally, there is evidence that without savings, people have no means of coping with even small financial shocks or unexpected expenses18. While those who keep savings in cash at home are vulnerable to theft (Kempson and Whyley 1999; Kempson et al, 2000) and do not benefit from interest payments (Kempson et al, 2005). 18 In respect to this point see the reference in note 11. 32 5 Existing policy approaches to financial exclusion Although various approaches have been adopted to achieve financial exclusion, these can be grouped into three broad categories: market responses, self-regulation and government intervention as facilitator or legislator. As will become clear, the various response models are more often mutually inclusive rather than exclusive. We have discussed each of these briefly below in general terms and in Table 7 we draw a map of the experiences matured in Europe, based on our knowledge to date – this will be up-dated in light of the information provided in the country reports19. 5.1 Market responses It is possible to identify two types of market responses: provision of financial services by niche providers, development of services by mainstream providers that are targeted on niche markets 5.1.1 Niche providers Traditionally, most EU countries have a range of banks or other financial institutions that have as a key objective the provision of financial services for people on low-to-moderate incomes and/or meeting the needs of disadvantaged or rural communities with limited access to financial services. They often operate only in a limited geographical area and are closely linked to the needs of that area, but are generally backed by a network providing expertise and professional management as well as a wide range of products to sell. These organisations include savings banks, post offices, credit unions and other mutual or co-operative providers. Such organisations are usually rooted in the history of the area in which they operate, but in some cases they have undergone major changes, such as loss of mutual or cooperative status or privatisation, which have sometimes led to a change in their historical mission, bringing it closer to that of commercial banks. In other cases, in order to ‘level the playing field’, there has been an erosion of the tax, legal, or other benefits that acted as compensation for the burden of serving ‘marginal’ market segments rather than just pursuing a profit. For these reasons, the country reports and our final report should consider the tendency of such institutions to change and the debate on the necessity to modify their status, along with the consequences that have resulted. 19 Unlike previous sections, this one is presented more as an overview with indications in the text of the way that the country reports might collect additional information for inclusion in the final report. 33 5.1.2 Development of new products and services by mainstream providers There are examples of mainstream providers developing new products and services for people on low-to-middle incomes as part of their normal commercial business. These include: design of products that are more appropriate to the needs of people who are financially excluded; working in partnership with not-for-profit organisations or government to reduce costs; reducing of barriers to access services and service delivery system; promoting initiatives to help the customer learn more about the banking system and about how the products on offer can help them meet their own needs. Product design Beginning with product design, some banks have developed simple, low-cost transaction bank accounts to meet the needs of people on low and unstable incomes. These take advantage of developments in technology – such as the use of electronic payments in place of cheques – to reduce the costs and risks of serving people for whom these would otherwise be a barrier. The use of mobile telephony for remitting money is another example. Reducing cost through partnerships Other developments involve partnerships with not-for profit organisations or government. A good example would be the Insurance with Rent schemes in the UK. These provide low-cost home contents insurance to low-income tenants living in disadvantaged areas where premiums would otherwise be high. Block policies are provided by mainstream insurance companies to social landlords who then act as an ‘agent’ for the insurance company, selling insurance to their tenants and collecting premiums with their rent. By pooling the risk premiums are kept low. Social landlords are paid a commission by the insurance company for acting in this way and this money is used either to reduce directly the cost of premiums for tenants or to pay for improved security on tenants’ properties – which reduces the level of burglaries and insurance claims and, in turn, reduces the level of the insurance premiums in the longer term. Other examples of partnerships designed to reduce costs include the UK matched savings scheme, the Saving Gateway, which has been operated by a commercial bank on behalf of the Government on a pro bono (non-commercial) basis, and banks providing loan capital and staff expertise to credit unions and other not-for-profit organisations so that they can widen access to affordable fixed term credit. Indeed credit is an obvious candidate for innovation in this area, since most people on low incomes want small, fixed term loans, which are costly to provide. Most mainstream providers set a minimum sum they are prepared to lend in this way, with revolving credit (credit cards and overdrafts) – which are shunned by those on low incomes - intended for smaller transactions. 34 Reducing barriers to access Innovations to reduce barriers to improve physical access include the establishment of outlets and offices open to the public in deprived areas. Innovation in service delivery has often been achieved through partnerships with intermediary organisations (e.g. post offices, credit unions and housing associations) that have the advantage of being closer to low-income market segments as well as offering lower distribution costs. The Bank of Scotland has, for example, worked with a tenants association in a poor neighbourhood of Edinburgh to offer branch services through their offices. Another example would be the Universal Banking Service through which post offices can be used to carry out day-today transactions with a basic bank account held with any of the main UK banks Partnerships with local not-for-profit organisations can also widen access to credit as they can use their detailed personal knowledge of their customers to facilitate more precise risk assessment and management procedure. Raising financial capability People at risk of financial exclusion often need encouragement to develop confidence in financial services and ensure that they are able to communicate adequately with financial intermediaries. A number of initiatives have been designed to tackle mistrust of commercial financial providers; targeting marketing and delivery at this market with easily understood, honest and comprehensive advertising and promotional material; working with trusted intermediaries (see above); and providing financial support for free and independent information and advice services. Corporate social responsibility has become an important part of the development, marketing and external communication strategies of profit-oriented institutions like commercial banks. As a result, a focus on marginal customers has become part and parcel of banks’ social responsibility agenda, with practical consequences both in the design of appropriate financial products to reach the financially excluded, and in the launch of initiatives to promote financial literacy. 5.2 Voluntary charters and codes of practice Voluntary charters and codes of practice, developed by the banks themselves through their trade associations to make provision for ‘life-line’ or ‘basic’ bank accounts, are a common response to financial exclusion. In many cases, these developments have been prompted and encouraged by governments concerned to increase social inclusion. As shown in Table 7, examples of this kind are found in France (the first movers in this direction in 1992), in Germany (1995 and under discussion today) in Belgium (1997) and in the UK (introduced in 2001 and extended a number of times since) The earliest of these voluntary charters was introduced in France in 1992. Developed by the French Banker’s Association it committed banks to opening an affordable account with facilities such as a cash card, free access to a cash machine network, bank statements 35 and a negotiable number of cheques. Nevertheless, the inefficiency of the charter drove the government to legislate about basic banking services in July 1998 (see below for further detail). In Belgium, a voluntary code of practice was introduced in July 1997 by the Belgian Bankers Association (ABB/BVV) following a report commissioned by the Ministry for Economic Affairs. This code provides for basic banking services for people on modest incomes who lack a bank account. At a minimum this ‘call deposit account’ offers three basic types of transaction: money transfers, deposits and withdrawals and bank statements – although individual banks may opt to offer other services if they wish. Up to three transactions a month can be made at a cost of less than 10 Euros per year. Some banks permit withdrawals using a cash card at a cash machine. All transactions are realtime and any that would take the account into overdraft are stopped. In Germany, despite a number of attempts to introduce a legal entitlement to a current account that did not carry an overdraft facility, a voluntary code was introduced by the German Bankers Association in March 1995. This makes provision for an ‘Everyman’ current account, offering basic banking transactions but without an overdraft facility. Individual banks have different interpretations of the ‘Everyman’ account. The extent to which this voluntary code has reduced banking exclusion is disputed. On the one hand, figures submitted by the banking industry to the Bundestag show that between June 1996 and June 2000 more than 800,000 ‘Everyman’ accounts had been opened – an increase of 350 per cent. Consumer representatives, however, question these figures. In particular, they claim that the majority of people opening these accounts are young people and not those on low incomes (Institut fur Finanzdienstleistungen, 2000). In the UK, there is a general Banking Code covering all aspects of customer service by banks, credit card companies and organisations offering savings accounts. This Code is underpinned by a detailed set of Guidance to subscribing companies and compliance with the Code is actively monitored by an independent body – the Banking Code Standards Board. The most recent edition of the Code gives an undertaking to make ‘basic bank accounts’ available to everyone who might benefit from one (see below for further detail). The effectiveness of such self-regulation should be judged by whether the expressed commitment meets local needs and demand, as well as the tone and extent of such commitment and the measures available to ensure that commitments are honoured and to encourage changes to bring voluntary charters or codes of practices more in line with what is needed. A good example in this regard is provided by the British Banking Code, which is periodically reviewed by an independent reviewer and where compliance is routinely monitored by an independent Banking Code Standards Board. This has included four mystery shopping studies to assess compliance with the basic banking commitment (see Banking Code Standards Board, 2005). 36 5.3 Government intervention Governments have intervened in two ways: as a facilitator of access to financial services and as legislator. 5.3.1 Government as facilitator Governments have acted as a facilitator to financial inclusion in a number of ways, including: providing an understanding of the problem promoting and supporting market initiatives contributing directly to the provision of financial services providing positive incentives to encourage the changes in the banking system to promote financial inclusion. tackling the reluctance to use financial services by those who are excluded. Governments have commissioned or undertaken research projects to investigate the causes of financial exclusion and recommending measures to combat them. They have taken steps to promote or support initiatives by commercial financial service providers. This includes encouraging banks to offer basic bank accounts, and promoting easier to access to the basic financial products provided by banks, for example through the post office network. They have also intervened in markets to stimulate low-cost low risk products – such as stakeholder pensions and the proposed ‘personal (pension) accounts’ in the UK. They have taken steps to assess the effectiveness of initiatives to promote financial inclusion, including verifying that financial products created to promote inclusion are actually meeting the needs of the target population and requiring scrutiny and approval of marketing material by an independent regulator. In some instances this has led to the establishment of voluntary codes and charters by financial service providers. Governments have also contributed more directly to the provision of financial services for people on low incomes. This includes the provision of funds for not-for-profit organisations (such as credit unions) that exist to meet the financial needs of people on low incomes. In other instances Governments have been the direct provider of financial services designed to meet the needs of people who are financially excluded. The UK Government’s Saving Gateway is a good example, as is the Child Trust Fund – a Government-led initiative to ensure that all children have a financial asset when they reach the age of 18. The final area consists of positive action: incentives aimed at encouraging the use of banking and bank products by people at risk of exclusion. These generally fall within one of the following four categories: tax relief (products free of tax or with tax benefits); guarantees to reduce credit risk and therefore increase creditworthiness; 37 occasional monetary incentives (such as bonuses and premiums under specific circumstances); incentives resulting from cooperation between public and private bodies, in which monetary incentives from private organisations, usually a not-for-profit institution, are matched by tax relief from the public body20. National and local governments can also play an important role in improving the overall climate in which such activity takes place, by raising awareness and improving the image of financial products and services, especially among the target population. Examples include the launching of free publications, seminars at secondary and post-secondary level, and the development of creative approaches aimed at adults. In the UK, the Government-appointed Financial Inclusion Taskforce has set up a national campaign, working with local organisations, to tackle the psychological barriers to using financial services. These initiatives have had the aim of helping people develop financial skills, as well as promoting the use of technology, encouraging confidence in financial providers, and strengthening trust in networks closely linked to the public sector, for example postal banking or savings banks. In some countries, these various functions are highly co-ordinated. In the UK this is being achieved through the Government appointed but independent Financial Inclusion Taskforce that is accountable to the Chancellor (Finance Minister) who, in turn, reports to Parliament. Its role is to find ways of ensuring financial inclusion, so it is, for example, monitoring progress by the banks towards halving the number of people without a bank account; working with banks to create better bill-payment services; overseeing the capital funds given to not-for-profit lenders to allow expansion of their services; providing finance for skills building among not-for-profit lenders; running a public campaign to overcome disengagement from financial services and overseeing the financial support for free independent debt advice services. Future work will include facilitating access to insurance and to savings. 5.3.2 Government as legislator Legislative action by governments to promote financial inclusion can be grouped in three main areas: direct legislation, which imposes upon banks and other financial intermediaries an obligation to provide, for example, universal banking services; indirect regulation, designed to remove obstacles that reinforce financial exclusion; indirect legislation to control providers that exploit the financially excluded. 20 It is easy to understand that, for reasons connected to the image of public policies, it is easier for public bodies to provide incentives in the form of tax relief (i.e., lower revenues) than as direct benefits (i.e., higher expenditure). 38 Direct legislation typically includes a legal requirement that every citizen/resident should have access to specific basic transaction banking services, as well as details of how they are to be guaranteed. These requirements usually apply either to specific categories of provider or to an entire range of banking institutions and financial intermediaries. The main purpose of such provisions is to define the types of services that make up the pool of ‘basic’ banking services, as well as pricing criteria and other requirements. Such laws exist in France and Belgium for instance. Indirect legislation, on the other hand, includes provision aimed at removing specific obstacles hindering the involvement of some people with the banking system. Such obstacles can include ‘blacklists’ of people who have failed to repay their debts in the past, or legal requirements concerning the verification of customer identity. Another example is the alleviation of the disproportionate impact of taxes on small transactions frequently undertaken by those customers at risk of exclusion. Indirect legislation has also been used to curb the behaviour of financial service institutions that seek to exploit people who are financially excluded. The French Government, for example, enacted legislation to curb the activities of rental purchase companies, whose charges for credit are high and lack transparency. 5.4 An overview of responses across EU countries Table 7 offers a preliminary picture of the state of our knowledge about the diffusion of the various kinds of responses adopted in various European countries. It will be expanded using information provided in the country reports. More detailed information is provided in Appendix II. 5.5 Summary and next steps In most European countries the financial services industry has high levels of solvency and efficiency and is able to respond quickly to the evolving needs of a changing economy. New technologies, higher living standards, new styles of living and working call for financial innovation as regards product and delivery channels. While the majority of people have access to a wide range of financial products, a minority is unable to access even the most basic financial services. There are big variations across Europe in both the level of financial exclusion and the severity of the problems caused by it, and the attention paid to these issues. Consequently the number and range of initiatives undertaken also varies widely. Financial inclusion is an important goal for an inclusive society, including providing basic bank accounts and offering appropriate payment services; bringing more people on low incomes into savings and asset ownership; promoting access to affordable credit and helping people when they find themselves in financial distress. Table 7 Overview of national responses to facilitate financial inclusion 39 Country Market responses Niche providers Austria Belgium Denmark Finland Government intervention Mainstream providers Voluntary charters and codes of practices + + (1997) As facilitator + (2003) France Post office. + (1992) + (2006) Germany Greece Ireland Savings banks. + (1995) + Italy In the past Post office & savings banks + migrants Savings banks. + migrants + (2003) + (1984; 1998; 2001; 2006) + Luxemburg Netherlands Portugal Spain As legislator + (2000 ?) Sweden United Kingdom Post office + (2001; 2003; 2005) + + This overview of responses to tackle financial exclusion is intended to offer a common framework both for the various country experiences which will be studied more in depth in the country reports and for the working papers dealing with special issues. To facilitate comparison of the experiences across countries, it would help greatly if the country reports adopted the categories and the concepts presented in this overview. Where this is not possible it would be helpful to have a clear explanation of why this is not appropriate for the context of a country. In all cases, descriptions of initiatives taken within countries should adopt a critical approach. This would include a discussion of their effectiveness and progress made against the agreed objectives (including how this was assessed) and highlighting what new priorities and direction for policy have been suggested as a result. 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Newcombe, R. et al (2002) Partnership to Promote Financial Inclusion: Housing Associations and Financial Institutions. Cambridge: Cambridge Centre for Housing and Planning Research. Nieri, L. (2006) ‘Access to Credit: the Difficulties of Households’, in Anderloni L, M.D. Braga and E.M. Carluccio, New Frontiers in Banking Services: Emerging Needs and Tailored Products for Untapped Markets. Berlin: Springer Verlag. O’Reilly, N. (2006) Three Steps to Inclusive Banking – Compliance, Standardisation & Innovation, London: National Consumer Council. Pilley, O. (2005) L’Union européenne et l’exclusion financière, in Gloukoviezoff G. (sous la direction de) Rapport exclusion et liens financiers. L’exclusion bancaire des particuliers. Rapport du Centre Walras 2004”, Paris, Economica. 45 Pollin, J.P. and Riva, A. (2002) Financial Inclusion and the Role of Postal Systems, in Ruozi R. and L. Anderloni (eds.), Modernisation and Privatisation of Postal System in Europe, Springer, Heidelberg New York. Randall, B. et al (2005) Community Access to Money: Housing Associations Lending on Financial Inclusion. London:Housing Corporation/University of Salford. Randall, B. et al (2006) Community Access to Money: Social Housing Landlords Reaping the Benefit . London: Housing Corporation/University of Salford. Rossiter, J. and Cooper, N. (2005) Scaling up for Financial Inclusion. London: Church Action on Poverty/Debt on our Doorstep Ruozi, R. and Anderloni, L. (2001) Modernisation and Privatisation of Postal Systems in Europe: New Opportunities in the Area of Financial Services, Springer-Verlag: Berlin Sinclair, S. (2001) Financial Exclusion: A Introductory Survey. Edinburgh: Heriot Watt University Centre for Research into Socially Inclusive Services Siewertson, H. et al (2005) Policy measures to promote the use of micro-credit for social inclusion, Amsterdam, Facet Test Achats (2001) ‘Budgets et Droit’ Test Achats No.158 . Paris: Test Achats Thrift, N. and Leyshon, A. (1997), ‘Financial desertification’ in J. Rossiter (Ed), Financial Exclusion: Can Mutuality Fill the Gap. London : New Policy Institute. Treasury Committee (2006a) Financial Inclusion: Credit, Savings, Advice & Insurance. London: House of Commons Treasury Committee: 12th Report of the Session 2005/06, Vol 1: HC 848-1 Treasury Committee (2006b) Banking the Unbanked – Banking Services, the Post Office Card Account and Financial Inclusion. London: House of Commons Treasury Committee: 13th Report of the Session 2005/06: HC 1717 Whyley, C. McCormick, J. and Kempson, E. (1995) Paying for Peace of Mind: Access to Home Contents Insurance for Low-income Households. London: Policy Studies Institute World Bank (2005), Indicators of Financial Access – Household – Level Surveys. 46 Annex I – Types of financial exclusion Terms Definitions Transactions Financial services using cash or other payment means (cheques, cards, electronic means) to make or receive payments, domestic or international. Therefore deposits are held mainly for transactions purposes. Savings Credit/Loan Insurance (risk transformation services) Additional information At a basic level, obtaining cash for personal use, withdrawing cash, converting cheques or vouchers to cash, paying bills through direct debit. Regular receipt of funds (income, benefit) Making remittances for migrants. At a more complex level, making or sending domestic payments through the financial network, receiving domestic funds through the financial network. At a higher level, sending and receiving cross border payments (different from remittances). Safeguarding wealth and Primary purpose is to safeguard accumulating wealth for wealth. High degree of liquidity future use required in case funds are needed immediately and high risk aversion. At a more complex level, earn a return on savings and increase their amount, for future use. (may involve some reduction in immediate liquidity, in exchange for a higher return: I suggest not to include this case. At a higher level, try to increase returns on savings through investment vehicles with some trade off in terms of liquidity/ riskiness Obtaining funds from a third Basic credit services would be party with a promise of short term loans for small repayment of principal, and amounts. in most cases with interest More complex services would be and arrangement charges in for longer duration and larger exchange for use of the sums. money Lines of credit / overdraft facilities which make funds available on a more flexible basis are more complex than basic loans. Payment of premium for risk The primary purpose of the service of an event happening, where is to manage risk around a specific payout is made if the event event that may occur (car /vehicle occurs. accident, fire, theft, damage, loss of crop?, business failure) or will occur (death, illness). 47 Relevant question mark Do the payment means imply a fiduciary relationship? (i.e. overdrafts?) Are there new technological /contractual solution that facilitate fiduciary payments by people with poor creditworthiness? Is the fiscal treatment an important element in determining convenience /incentives? Are overdraft facilities considered essential in a banking relationship for some (what segments?) of customers? If yes, how to mach demand and offer side? Are there new products targeted to riskier people? Annex II - A synthesis of the main experiences of responses Voluntary charters and codes of practice Country Year of first Name Main provisions introduction Charter on bank services It was intended to enhance the “right-to-the 1992 FRANCE established by the Comité Consultatif and signed by the Bankers’ Association account” of the Law and integrate it on a voluntary basis, but it was considered too vague and ineffective. The banking services included in the basic banking offer were not based on the principle of free service. The application of this charter has been challenged by consumer associations. BELGIUM 1997 Charter of the Association Belge des Banques for a basic banking service According to this Charter, the banks that subscribed committed themselves to provide basic bank services to everyone with a legal domicile in Belgium. This service was then made available to physical individuals who could then access a current account which offered three basic functions: i) monetary, manual and electronic payments, ii) deposits and withdrawals, iii) account statements GERMANY 1995 Charter of the Central Credit Committee (a lobby organisation of all German banking associations “Girokonto fur Jedermann” UK 2005 and Banking Code (and related monitoring This code of conduct is a recommendation suggesting to all associated banks to provide a current account to anyone without looking at the income situation. This voluntary code of conduct also names circumstances which make it unreasonable for a bank to offer a current account. If a bank wrongly refuses to open a current account, the concerned customer can file a complaint to one of the complaint offices of the four major banking associations. The issue of basic bank accounts is discussed (in the current version issued in March 2005) in the sections Other notes and criticism For people on low incomes, it included the possibility of an ATM card as well as a free access to the ATM dispenser of the bank, the possibility of long-distance payment, the availability of relevés d’identité bancaire (RIB) or banking identity statements, and a system of cheques whose number could be limited with the customer’s agreement While the relevant consumers’ associations approved this formula, they were also critical because the banks scarcely applied it to marginal clients at all, even though they had originally committed themselves to doing so. There has also been criticism because the evidence shows that accounts have tended to be opened not by people at risk of financial exclusion, but rather by people taking advantage of a product that is cheaper even though its functions are more limited. This criticism of self-regulation paved the way for the Law of 24 March 2003 previous editions ITALY initiatives) Patti Chiari Charter Standard Basic Account about key commitments and the provision of support in choosing the products and services which best suit the customer’s needs. In the first section, though no specific commitment is set out to serve customers with basic knowledge and needs, the first two paragraphs of the section are clearly designed to meet the requirements of this market segment. In the same section, more explicit reference to basic accounts and their relation to needs is made. Paragraph 3.1. reads: “We will assess whether your needs are suited to a basic bank account (if we offer one) and if they are we will offer you this product”; also, “We will offer you a basic bank account if you specifically ask, and meet the qualifying conditions for one”. The following paragraph, 3.2. reads: “Where we offer basic bank accounts, we will tell you if they can be used at post office”. Furthermore, a clear definition of a basic bank account is provided in the Glossary: “A basic bank account will normally have the following features: - Employers can pay income directly into the account. - The Government can pay pensions, tax credits and benefits directly into the account. - Cheques and cash can be paid into the account. - Bills can be paid by direct debit, by transferring money to another account or by payment to a linked account. - Cash can be withdrawn at cash machines. - There is no overdraft facility. - The last penny in the account can be withdrawn”. It should be noted that the guide for subscribers to the Banking Code specifies that, if the customer has a history of fraud or unpaid debt, a subscriber is not bound to open an account, and also that “if the customer already holds a suitable account with the bank, a subscriber is not bound to open a bank account”. Under the basic banking service initiative, all participating banks are required to offer a standard basic account (i.e., an account which has the same content across all banks), but each bank is also free to apply its own pricing policy. 49 Participation is on a voluntary basis: the Patti Chiari charter is made up of single initiatives (i.e., it is not a ‘package’) and each bank is free to choose which Italian basic bank accounts provide the following standard services: i) crediting of wages or pensions; ii) cash and cheque deposit; iii) cash withdrawal directly at the teller’s; iv) payment by bank transfer, both from and into the account; v) bill payment and other regular, recurrent payments; vi) use of a cash card to withdraw cash from all the issuing bank’s ATM facilities, or alternatively, a prepaid stored value card; vii) investment of savings through regular payments; viii) home and/or phone banking facilities to obtain information and manage transactions; ix) regular account statements. The basic banking service does not include a chequebook, credit card, any kind of loan or credit or the purchase of bonds. In compliance with antitrust regulations, each bank sets its own prices independently, having regard to its own sales policies and operational constraints. Consistent with the spirit of the initiative, charges should ideally be kept to a minimum and be divided into a flat rate for a fixed number of transactions, and individual commissions for each additional transaction above that ceiling. Overall, the range of charges and services available is wide and varied though, as already mentioned, stamp duties do have a particularly heavy impact on charges. Moreover, no statistical data is available on the actual spread of basic banking services; similarly, no ‘high visibility’ mass advertising campaign about basic accounts appears to have been launched in the Italian media, although such campaigns would be consistent with the aim of targeting customers with basic financial needs. 50 initiatives it will take part in. Government intervention (as facilitator) Country Name of the Initiative Main provisions Promotion of the Universal One important spur to account ownership amongst those without accounts was provided UK Bank Offer and Post Office Account Financial Inclusion Strategy Financial Inclusion Taskforce Financial Inclusion Fund by the Treasury’s decision to pay all welfare subsidies, allowances, benefits and state pensions direct to beneficiaries’ accounts. Since the Spring of 2003, this system has been progressively automated and has been closely tied to the Universal Bank, which in turn was the result of the joint action of three partners: the Treasury, the Post Office and the banking system. The Universal Bank is a scheme – jointly funded by the public and private sectors – by which any holder of a basic account with a major bank can use local post offices, (which may be closer to his/her home or workplace) for routine bank transactions such as withdrawals and cheque cashing, at no additional cost. Furthermore, the postal system has itself developed a special kind of basic account offering an intentionally limited range of services, at a lower cost. This product, called Post Office Card Account, consists in a card-based account to which only state benefits, subsidies and pensions, and no other kind of income, can be paid. In a nutshell, it is a kind of electronic purse or prepaid stored value card, and has been popular with pensioners. In all, 17 banks, including all major credit institutions, offer banking accounts that can be used at post offices. The Government set out its strategy to tackle financial exclusion in ‘Promoting financial inclusion’, published alongside the 2004 Pre-Budget Report. The report sets out a range of measures – in three priority areas – access to banking, access to affordable credit, and access to free face to-face money advice. In order to guarantee the practical application of the commitment is was decided to establish a Financial Inclusion Task Force and a Financial Inclusion Fun The Financial Inclusion Taskforce was formally launched on 21st February 2005 and will monitor progress on the objectives the Government has set out and will make recommendations on what more needs to be done. It has a budget of £3 million to pursue their objectives, including improving the knowledge base of financial exclusion issues. The Task Force works closely with consumer and bankers’ organisations to identify issues to be put on the policy agenda The Financial Inclusion Fund of £120 million over three years was announced in the 2004 Pre-Budget Report in December 2004. The Fund will support initiatives to tackle financial exclusion: £45million is being used to support an increase in provision of face-to-face money advice, and is being administered by the Department of Trade and Industry. Funding commenced in April 2006 and more than 3500 clients advised by end of October 2006. £36 million is being used for a Growth Fund to enhance the coverage, capacity and sustainability of third sector lenders. This fund is being administered by the Department of Work and Pensions. £10 million has been made available for the administration of the Growth Fund and a scheme to enable third sector lenders to apply for repayment by deduction from benefit where normal repayment arrangements have broken down. £6 million is being used by the Legal Services Commission to pilot mechanisms of 51 money advice outreach aimed at those who do not normally present themselves to debt advisers FRANCE GERMANY National Council to combat exclusion Financial Services Consultative Committee Settled in September 2005 The agenda for the Action Plan launched in 2004 included four main objectives: 1. the right of access to an account for all; 2. access for all to a bank card and modern payment methods; 3. targeted communication with people who are not entitled to hold a cheque account; 4. the widespread acceptance of “modern payment methods” by public services in the local area. As to the first issue the Committee gave a boost to the subscription of a letter of commitment to activate a new procedure to designate a banking establishment – that gives the right to an account to the people to whom this right has been denied. Now, any bank that has refused to open such an account has to undertake formalities with the Banque de France and there is a stringent timescale for handling the procedure both by the bank as well as by the Banque de France. The client should be informed of the banking establishment nominated, within two days. Besides the subscription to the letter of commitment to activate the new procedure, the engagement includes training initiatives for the counter’s staff, communication campaigns organised by the Ministry for Economy addressed to the population, monitoring of the operation of the procedure. As to the second issue the Committee hurried up the banks to introduce these new instruments and procedures and the public sector encouraged the spread of these payment mechanisms by accepting them in the local area and providing financial support. The German Federal Government is committed to improve access for low-income groups of people to basic banking services, and is currently working together with the banking industry to access and improve the existing situation. 52 Government intervention (as legislator) Country References Main provisions BELGIUM Law 24 March 2004 (Law introducing a basic banking account)) Further details Further provisions Elements to be analysed in order to identifying the Costs and Benefits The law obliges all banks to provide a basic banking account to any individual who does not already have one, or a yearly fee of maximum EUR 12. The basic banking service covers the following operations: opening, managing and closing the account:; money transfers and payments (manual and automatic); standing orders and domiciliation; money deposits; money withdrawals (manual and automatic); account statements - According to the “pay or play model” a compensation fund managed by the Belgian Central Bank and supplied with the bank system’s contributions, reimburses banks that open and manage a larger number of accounts than their own economic importance in the Belgian market would justify. - Sanctions are imposed on those banks that do not respect the rule. - The scheme is monitored by the National Bank of Belgium that collects statistics on the number of basic bank account opened. What is the assessment of the application of the law by: Central bank, Consumers’ Association and the Banking Industry? The law introduced the right to a basic bank account The right concerned a deposit account in which all transaction took place in cash The law limited the conditions under which banks limit the opening of a bank deposit account to basic banking services It extended the “right-to-the-account” procedure to all physical and juridical people that are established in France. It set the principle that in cases where the “right-to-an account” has been invoked the pricing of services offered should be fixed by a decree. It defined the range of services considered to be basic services. The basic services included are: i) account opening, maintenance and closure; ii) one change of place of residence per year; iii) issuing, upon request, of bank or postal identity document; iv) receiving bank or postal transfers; v) monthly statement of all transactions carried out on the account, sent to account holder’s address; vi) cash transactions; vii) collection of cheques or bank and See also Charter for a minimum banking service FRANCE Law n° 84-46 of 24 January 1984 (the Banking Law) Law n° 98-657 of 29 July 1998 Law n° 99-532 of 25 June 1999 on saving and financial security See also CHARTER for basic bank services (1992) 53 The supervisory body is entitled to intervene to enforce the implementation of the right. However, evidence shows that appeals have been limited in number although the banks have applied severe conditions to other services related to these accounts. In particular so-called “payment incidents” have been penalised. To combat the extremes of this practice, a further decree (see below) has established a limit to the charges that Law n° 2001-1168 of 11 December Decree n° 2006-384 of 27 March 2006 on basic banking services FINLAND Credit Institutions Act (31.1.2003), Section 50a PORTUGAL Decree n°7-C/2000 March 2000 The law introduced measures to combat the common practice of imposing severe penalties for payment incidents, that occurred mostly to people on low incomes, with low cultural level and poor socio-economic conditions The law set the mandatory obligation to all banks to offer alternative payment mechanism to persons who are not entitled to a chequebook or a credit card.. It states that a regular bank account and the means necessary to use such account can only be refused if there are weighty grounds for the refusal. Banks’ compliance with the decree is voluntary, but most of them adhere. 54 postal money order; viii) deposit or withdrawal of cash at the counters of the bank where the account has been opened; ix) payments with withdrawal and use of inter-bank payment facilities or bank or postal money order; x) facilities for accessing details of balances at a distance; xi) a payment card requiring systematic authorisation (if provided) and, if not, a withdrawal card for weekly withdrawals at automatic teller machines of the bank where the account has been opened; xii) two bank cheques per month or equivalent payment mechanism providing the same service. . can be imposed for modest bad cheques. Individuals who are not considered sufficiently reliable and trusted to use fiduciary payment instruments which involve risk for the issuing bank can now use alternative payment mechanisms without resorting to cash. These are payment cards with systematic authorisation and other alternative payment mechanisms The grounds shall be linked to the customer or his earlier behaviour or to the fact that there is evidently no actual need for a customer relationship The customer has to be notified of the grounds for the refusal Is it possible to provide an assessment of the result of the diffusion and functioning of these new payment instruments and procedures? Consumers associations state that basic banking services are essential services in modern society and that this legislation is not enough. Elements of the debate? Is this updated?