On 27th January 2021 the OBIE convened an expert panel to discuss the role that open banking can – and indeed should – play in addressing vulnerability.
Revisit the recording of the OBIE’s Consumer Forum event from 27th January 2021, which featured the insight and contributions of:
Who defines vulnerability? How should your financial data be interpreted, and who decides whether you match the definition? Who acts on this decision?
These big questions inspired a highly engaging discussion at the OBIE’s most recent Consumer Forum in January 2021.They’re not simple, and they sparked a discussion on the broader use of data and the morality of making assumptions on an individual based purely on interrogation of that data.
With the FCA suggesting that nearly half of all UK adults could be financially vulnerable, we probed how open banking could enable better products for everyone, no matter what life throws at them.
Vulnerability to what?
Chris Fitch, Vulnerability Lead at the Money Advice Trust, argued that any discussion had to start with the specifics: “What is the customer actually vulnerable to?”
He returned to this point again and again – explaining that we have to think beyond assumed causes or overly-broad definitions.
“Life events, health conditions, financial resilience, financial capability – these don’t tell us about harm, don’t tell us about detriment, or the pain a customer may face. They don’t provide guidance to the outcomes a consumer might face and, therefore, the action we need to take.”
Building a bridge to better financial behaviour?
Diane Burridge concurred in challenging the idea of ‘vulnerability’ as a monolithic concept. She used the phrase ‘State, not Fate’ to distinguish between an individual’s financial history and circumstances, and their future behaviour if certain vulnerabilities or other external factors could be addressed.
She went on to explain that, in the course of using open banking data in their credit underwriting service, Moneyline are moving towards being able to direct customers towards non-financial support systems for vulnerabilities that might be indicated in their financial data.
She said: “Where we can’t help responsibly with a credit product, we look to ways we can help maximise financial resilience. The rounded picture of circumstances with open banking data acts as a triage so we can signpost different forms of help in an informed way.”
But who designs the bridges?
The question of ‘informed support’ and intervention led to a hotly debated talking point: who makes the judgment that someone needs help? And, crucially, how to ensure that any such intervention is meaningful?
Dr Leda Glyptis of 10x Future Technologies was clear that this responsibility should not sit with banks – and indeed could not.
She explained that, while banks sit on lakes of data, the data isn’t structured in a manner that can be easily interrogated. So, due to systems, policies, talent, and resource, “unless you can ask clever questions, you don’t get the right information back.”
And that is why, as she went on to say, “[Banks] are part of the solution rather than the solution. They should participate in discussions, so that we can get to a place where servicing vulnerable customers and communities is something you can do as part of your normal business.”
Big data. Bigger questions.
This idea of ‘data lakes’ and the sheer masses of information being held within financial institutions raises another point – that of privacy.
Moving the conversation beyond the confines of open banking, Joe Gladstone argued that the metaphorical data genie has been let out of its bottle, never to be put back in. He went on say that, while open banking is a ‘gift’ for the purposes of understanding customers, society was lagging behind what is technically possible.
This perspective is not often aired at our Consumer Forum events – and sparked renewed debate within the panel – summed up by Chris Fitch when he posed the question, “just because we can do it, should we do it? And if we should do it, are we ready?”
The customer must always come first
Open banking – the data it leverages, and the services it enables – is ultimately focussed on empowering each of us with the potential of our financial data. And, our panel all agreed, the key to unlocking that potential in a responsible and ethical way is to ensure that Customers are at the heart of product development.
Designing simple, clear and effective propositions, with end user input, will be the key to realising the opportunity of open banking beyond simply developing products, but in transforming the financial experiences of all of us – and especially the vulnerable within our society.
By improving the focus on actual vulnerabilities, and by bringing ‘real people’ into the heart of design alongside Product Managers, Chris laid out a route towards addressing the outcomes of these vulnerabilities effectively using open banking data.