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Response to the Banking Standards Board consultation

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What do good banking outcomes look like to consumers?

We welcome this consultation and the development of a framework to establish what good banking outcomes look like for consumers. We have focused our specific comments on some of the questions.

Consumer principles:

1. Do you agree with the consumer principles listed in the framework?

We consider the consumer principles listed in the framework to be comprehensive and covering the main areas of focus. These consumer principles align with our understanding of our experiences with our clients and some of the barriers they can face when engaging with their bank.

2. Do you think that focusing on consumer outcomes is a good approach to raising standards in the banking sector? If not, what are your concerns and possible alternatives?

The approach of focusing on outcomes and having ‘real life’ examples is welcome as provides a useful illustration of what the outcomes would mean for both banks and consumers. It also differentiates this framework from the FCA rules. Having a clear, focused outline of what good consumer outcomes for the banking sector will give a realistic goal for the banking standards board, consumer groups and banks themselves to work towards.

Outcomes-based approach:

4. Is an outcomes-based approach likely to be effective for this work?

Taking an outcomes based approach should allow there to be effective measurement of whether banking standards are being raised to improve consumer outcomes.

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