Memorandum submitted by Lloyds TSB
1. EXECUTIVE
SUMMARY
1.1. Lloyds TSB is one of the UK's largest
corporate givers through cash giving, gifts in kind and charitable
donations.
1.2. The Bank is committed to ensuring that
its own products and delivery channels are suitable for those
who have previously not been able, or not felt able to use its
services. We have opened 348,000 basic bank accounts since April
2003 and believe this represents around 20% of all basic bank
accounts opened since then.
1.3. With one of the largest networks of
branches and cash machines in the UK and as one of only a few
high street banks to allow customers to carry out essential transactions
at the Post Office, customers of Lloyds TSB are able to access
their accounts in more ways than ever before.
1.4. Lloyds TSB supports a number of new
and innovative initiatives designed to serve the needs of people
who find themselves financially excluded and has been instrumental
in developing new, not for profit community based finance initiatives.
1.5. Support for money advice amounts to
some £2 million per annum and our work leading the FSA's
Financial Capability Workplace workstream makes a valuable contribution
to the financial capability agenda.
1.6. Financial exclusion is a complex area
that requires a partnership approach between banks, Government
and community groups such as credit unions, housing associations
and other local organisations.
2. INTRODUCTION
2.1. Lloyds TSB is one of the UK's leading
financial services groups, whose businesses provide a comprehensive
range of banking and financial services to around 16 million customers.
Employing around 70,000 people, the Group is a major contributor
to the UK economy and the communities in which it operates.
2.2. As a result of the merger between Lloyds
Bank and TSB in 1995, the combined Lloyds TSB Group has one of
the largest single brand networks of branches in the UK and Lloyds
TSB Bank's customer base is closely representative of the UK population
as a whole. It is, therefore, highly committed to promoting financial
inclusion through accessibility to the products and services it
provides.
Corporate Responsibility
2.3. The Group is one of the UK's largest
corporate givers, contributing over £35.5 million in 2004
through cash giving, gifts in kind and charitable donations.
2.4. The Lloyds TSB Foundations is one of
the UK's largest grant making trusts and each year receive 1%
of the Group's pre-tax profits averaged over three years. Since
1997, the Foundations have received £228 million to distribute
to local, grassroot, community causes and in 2005, the Foundations
received £31.2 million to distribute to registered charities.
In the last two years, £472,000 has been contributed by the
Foundations, directly to financial inclusion projects such as
funding money and debt advice.
3. ACCESS TO
BANKING SERVICES
3.1. Since April 2003 and the automation
of benefit payments, benefit recipients have been able to choose
between having their benefits paid into the Post Office Card Account
(POCA) or a bank account. We continue to believe that this free
choice for consumers is important and four million POCA customers[180]*
clearly value their ongoing relationship with the Post Office.
3.2. In December 2004, Lloyds TSB agreed
with the industry and Government to work together towards the
goal of halving the 2.8 million adults in households without a
bank account and of demonstrating significant progress in that
direction within two years. The industry has made good progress
towards that goal over the last 12 months and has opened 1.52
million basic bank accounts since April 2003.
3.3. Research conducted by Millward Brown[181]
on behalf of the British Bankers' Association (BBA) in the autumn
of 2005, to which Lloyds TSB contributed funding, found that around
half of respondents who had opened accounts in the last 12 months
had previously held no other bank account. If this research is
a representative sample, this suggests that half of all those
basic bank accounts opened by the industry in the last 12 months
have been opened by people who were previously unbanked. The banks
are, therefore, on track to meet the shared goal within two years.
For Lloyds TSB, the proportion of unbanked is somewhat larger.
76% of Lloyds TSB basic bank account customers who participated
in the Millward Brown research had not previously held a bank
account of any kind.
3.4. Lloyds TSB has, therefore, made a significant
contribution towards this goal. Since April 2003, we have opened
348,000 basic bank accounts (Basic Bank Account and Cash Account,
which are outlined below). This is believed to be around 20% of
the total number of basic bank accounts opened by the industry
since April 2003, which is broadly in line with our natural market
share for current accounts.
3.5. There is a cost to the Bank in opening
and running basic accounts. With an average balance of £371,
these accounts generate little income from interest and as Cruickshank
noted, during a period of higher interest rates it took an average
current account balance of £1,175 to generate income for
suppliers. However, we operate these accounts in recognition that
we have a role to play in supporting greater financial inclusion
and creating greater access to mainstream financial services.
3.6. At Lloyds TSB we offer two basic bank
account products to new customers, the Basic Bank Account and
Cash Account. Although these have served our customers' needs
well in the past, we are considering rationalising our two products
into one in order to reduce the current product complexity and
maximise efficiency whilst still meeting the needs of our customers.
When these changes are implemented, all applications will be checked
and verified in branch by staff prior to processing. We also intend
to give customers the option of a debit card for use in shops
etc, which would not allow them to go overdrawn. We believe that
this added functionality will be of benefit to our customers.
The Basic Bank Account
3.7. The first element of our existing basic
bank accounts is the Basic Bank Account and these accounts comprise
seven% of the basic bank accounts we opened in 2005. This is a
very simple account designed for those people whose income is
from Government benefits only. Customers are able to withdraw
cash, make deposits, check balances and set up standing orders
and direct debits. Neither overdrafts nor cheque books are available
on this account.
3.8. Basic Bank Account customers receive
(on average) more direct credits into their account each month
than our other customers. Fewer than 40% of our customers have
direct debits set up on their account and prefer to use cash machines
and post offices to withdraw cash. No fees are charged for returned
items.
3.9. Our application form is designed to
be as easy to understand as possible and customers are able to
complete the form in their own time and once completed, send it
and supporting documents to our processing centre, via the post,
so that the account can be opened. Applicants are required to
send original documentation for the purpose of proving identity
and address, however, the process is based on using only "low
value" documents (eg a benefit letter for identity). Staff
in all of our branches are on hand to answer any questions customers
might have when filling out the application form. Staff at our
processing centre may also contact customers directly in the event
of there being errors on the application form once it has been
completed and returned.
3.10. A copy of our Basic Bank Account literature
is enclosed with this submission.
3.11. The Millward Brown research, referred
to earlier, asked customers to rate their satisfaction with the
account opening process and 67% of all customers who have opened
accounts in the last 12 months said they were satisfied with the
way the account opening was handled.
Cash Account
3.12. The Cash Account is the second strand
of our existing basic bank account products and comprises 93%
of our basic accounts. It has similar functionality to the Basic
Bank Account, but is designed for customers who would not meet
the requirements for our standard current account, Classic Account
and whose main income is from sources other than Government benefits
and less than £500 per month.
3.13. As these customers are in receipt
of income from sources other than just benefits, they are historically
more likely to want, and be in a position, to upgrade their account
to a standard current account. In 2005, we upgraded around 8,500
Cash Accounts to standard current accounts.
Identification and address verification
3.14. Ensuring that we adequately confirm
the identity of applicants for all our accounts is a high priority.
We do, however, experience twice as many applications that turn
out to be fraudulent for our basic bank accounts than any other
current account.
3.15. We recognise that some customers,
including those with low incomes, do not possess standard forms
of identification such as a passport or driving licence and we
have offered, for many years, greater flexibility in the forms
of identification we are able to accept for all of our accounts.
We accept an original Benefit, Pension or Tax Credit notification
letter confirming a customer's right to benefit/tax credit as
proof of identity for customers opening any account and for proof
of address, we accept a range of documents including a credit
union statement, notification of housing benefit from a local
authority, local authority tax bill or utility bills. Branches
also have access to a central specialist helpdesk which provides
guidance in more difficult cases.
3.16. Preventing money laundering is a significant
cost to the industry, which last year spent £250 million[182]
complying with money laundering regulations. There is sometimes
a fine balance to be struck between ensuring that we maintain
regulatory standards to meet our anti-money laundering obligations
without creating a barrier which prevents genuine customers from
accessing the banking system—we are mindful of this balance
and regularly review our policies and procedures.
3.17. Fraud is also a growing area of concern
and last year non plastic card fraud alone rose by 11%, costing
the banking industry £108 million[183].
Although our basic bank accounts make up 3% of our entire current
account book, fraud on these accounts represents over 20% of fraudulent
or suspect activity. We must also be aware of the growing threat
of identity theft as a means of committing fraud and it is therefore
essential that we continue to remain vigilant in all aspects of
identity verification and this constitutes additional cost for
the business.
3.18. Both our Basic Bank Account and Cash
Accounts are open to anyone, except undischarged bankrupts and
people with a history of fraud. Therefore, whilst we do credit
check these accounts, it is only for the purposes of screening
out these two categories of customers. Any other applicant will
be offered an account and their credit record with the credit
reference agencies will not be impaired by the credit check.
Marketing of basic bank accounts
3.19. Full details of both of our basic
bank accounts are available in our branches and on our internet
site.
3.20. We recognise, however, that special
efforts are sometimes required to reach out to the financially
excluded and we have therefore previously provided every credit
union in Great Britain with posters advertising our basic account
for display in their office/collection points. We have also worked
closely with a number of specific credit unions and CDFIs over
the last few years. For example, Change[184],
which was contracted in 2004-5 by the Department for Work &
Pensions, to help migrate around 125,000 London residents to Direct
Payment.
4. DISTRIBUTION
4.1. With around 2,000 branches, over 4,200
ATMs, post office access, internet and telephone banking, customers
of Lloyds TSB are now able to carry out their banking in more
ways than ever before.
Branches
4.2. Retail banking in the UK has experienced
major changes in recent years, driven by changes in consumer demand,
competitive pressures and technological developments. Research
by Booz Allen Hamilton revealed that 80% of bank/customer relationships
are forged in the branch and for that reason, the branch remains
at the heart of our customer strategy. At Lloyds TSB, we continue
to have one of the largest networks of branches and free cash
machines of any bank.
Table 1.2: Branch and ATM networks (Source:
APACS)
4.3. Customers are, however, increasingly
making use of new, more convenient channels such as cash machines,
the telephone and internet (use of internet banking has doubled
in the last four years[185])
and as an organisation we must constantly strive to meet and anticipate
our customers' requirements. The size and shape of retail banks'
network have therefore been reshaped to meet these changes in
usage patterns.
4.4. At Lloyds TSB, the Bank has also restructured
its network to meet the needs of customers as well as merging
those duplicate branches, where, as a result of the merger between
Lloyds Bank and TSB, there were branches of Lloyds Bank and TSB
within half a mile of each other, in many cases on the same high
street. This has enabled us to realise business effectiveness
without material adverse impact on our geographic coverage.
4.5. There are also instances where we have
decided to close branches, for example, where there are issues
in connection with the lease that cannot be resolved, security
concerns for our staff and customers, there are poor facilities
or are not fully IT equipped and therefore require significant
investment to bring them up to the same high standard as our other
branches. Last year we closed a total of 10 branches, predominantly
for these reasons.
4.6. Since 2002, some 750 branches have
benefited from £56 million in investment for refurbishments
and upgrading of facilities. A further £34 million is forecast
for investment in the next two years.
4.7. 76% of the UK population live within
three miles of a Lloyds TSB branch.
Table 1.3: Percentage of population within 1,
3 and 5 miles of financial services access. (Source: Internal
Data, May, 2005).
Post office access
4.8. Lloyds TSB was the first bank to agree
an agency arrangement with the Post Office whereby its personal
customers can use the post offices to carry out essential banking
transactions, such as deposits and cash withdrawals. This arrangement,
whilst helping to underpin the future viability of the Post Office
network, costs the Bank a significant amount of money each year.
We recognise the value of this service to our customers, which
means that over 99% of the population are within three miles of
either a post office or branch of Lloyds TSB.
4.9. We see the Post Office as providing
a useful supplement to our branch network, providing access to
branches for our personal customers in areas where our representation
is sparser. With over 14,500 locations, post offices provide an
unrivalled geographic coverage and we have no current plans to
change this arrangement.
4.10. Consequently, we see little current
need for a network of shared branches as has been proposed by
some pressure groups as we believe that our customers' requirements
are well served by our existing branches, new channels such as
the internet, telephone and post offices. Indeed, Lloyds TSB participated
in a shared branch pilot with Barclays, Natwest and HSBC in 2002
and customer usage in the pilot areas did not support wider roll
out. In those areas where the pilots were active, usage of the
Post Office by our customers declined and a network of shared
branches would therefore undermine the viability of local post
offices.
Cash machines
4.11. Cash machines are a vital part of
the overall service we provide for our customers and with 4,220
cash machines, we have the second largest network of any bank
in the UK. In recent years, we have responded to customer demand
by expanding our network of remote cash machines, providing 24
hour access in more locations. In the last two year, we have installed
around 300 new cash machines in remote locations. Withdrawals
at all of our cash machines are free to both customers and non-customers
and we do not charge our current account customers for making
withdrawals from the other 33,000 LINK cash machine.
4.12. Whilst the number of surcharging cash
machines has been increasing more quickly than non-surcharging
cash machines in recent years and nearly 40% of all cash machines
are now surcharging, the vast majority (97%) of transactions carry
no surcharge.
5. ACCESS TO
AFFORDABLE CREDIT
5.1. Lloyds TSB is committed to supporting
access to mainstream financial services, including affordable
credit and to responsible lending. However, there is a point at
which these objectives can conflict. Banks are often criticised
for making it "too easy to get credit" and at the same
time "too difficult for the financially excluded to obtain
credit". It is therefore important to recognise that there
is a point at which banks should be allowed to exercise their
discretion in choosing customers according to their risk appetite.
5.2. There will always be a certain segment
of customers to whom it is not commercially viable for banks to
lend and those consumers are better served by different and alternative
sources of affordable credit. We believe that the Government is
best placed to provide the necessary support for the most vulnerable
in society and we therefore welcome the reforms to the Social
Fund announced in the Pre Budget Report, December 2005.
5.3. We do, however, believe that we have
a valuable role to play in supporting access to alternative forms
of credit, for example from credit unions and CDFIs and we have
a well established track record of support in that area.
Community finance
5.4. For a number of years, Lloyds TSB has
supported the development of new and innovative ways of reaching
customers who find themselves excluded from mainstream financial
services. Whilst these initiatives are not necessarily commercially
profitable for us in the short-term, we believe we have a mutual
interest in supporting local enterprise. This leads to a more
prosperous local community, which in turn offers us potentially
profitable business opportunities in the long-term.
5.5. We have provided sole development funding
for a new Community Banking Partnership (CBP), supporting the
work of think tank, the New Economics Foundation (NEF), the National
Association of Credit Union Workers, and Salford University. The
CBP aims to provide financially excluded households with a seamless
service offering savings facilities, affordable loans, access
to basic banking services, bill and debt repayment systems, money
advice and support. In 2005, a number of pilot community banks
have been established providing a one-stop financial service including
savings, affordable loans, money and debt advice and basic bank
accounts.
5.6. Funding has been provided for several
other community finance initiatives including Financial Inclusion
Newcastle, the Wessex Reinvestment Trust, South West Investment
Group, PRIME, One London Limited, the Lincolnshire Loan Fund and
South Coast Money Line.
5.7. These initiatives provide loans to
individuals and businesses, or invest in enterprises in deprived
communities. While requiring a financial return, managers of these
funds also have a social objective and are under less pressure
to maximise commercial returns.
5.8. Lloyds TSB was instrumental in working
with the University of Salford to develop not for profit community
based finance initiatives. The model first launched through South
Coast Money Line (please see below) helped to create a blueprint
for local solutions for providing access to affordable credit
and has been repeated in numerous areas across the UK.
5.9. These organisations offer a range of
loans covering diverse requirements from debt refinancing, to
home improvements and business start-ups.
South Coast Money Line
Formerly known as Portsmouth Area Regeneration
Trust, South Coast Money Line (SCML) first opened its doors in
July 2000 and was developed in partnership with Portsmouth Housing
Association and Salford University. Now in its fifth year of trading,
total lending has reached over £1 million and over 1,200
loans have been made, 99 jobs created and 70 safeguarded. SCML
has also helped to support 102 new business start-ups and over
4,000 people in the Portsmouth area have been given personal advice
or referred on to another agency.
Of those customers of SCML, 71% are on income
benefit and over 45% live in social housing.
Lloyds TSB provided funding, premises and a
secondee to set up the scheme.
Credit unions
5.10. Lloyds TSB has a long history of support
for credit unions and provides banking facilities to over 200
credit unions in the UK. Our Credit Union Bank Account offers
free day-to-day banking with no limit on the number of deposits
or withdrawals.
5.11. Lloyds TSB has provided support to
credit unions in helping them to get started and establish themselves
in a way which will allow them to be self-supporting and most
importantly, successful. We have provided support such as seedcorn
funding, rent free premises, expertise and advice to over 30 credit
unions including Ely in Cardiff, Llanelli, Burnley, Cranhill,
Skelmersdale and Weston-super-Mare credit unions.
5.12. Credit unions have an important role
to play in society and we welcome the Chancellor's commitment
in the Pre-Budget Report to increasing the maximum rate of interest
that credit unions can charge on loans, from 1% to 2% a month.
6. FINANCIAL
EDUCATION AND
ACCESS TO
FINANCIAL ADVICE
Access to free money advice
6.1. Lloyds TSB has long supported access
to free, independent money advice and last year contributed around
£2 million in funding to the money advice sector:
— We have committed to provide £1.5
million of funding to the Money Advice Trust (MAT) over three
years.
— We also provide a contribution to
the Consumer Credit Counselling Service (CCCS), where our contribution
is calculated as a percentage of monies collected. In 2005 this
totalled over £1.1 million.
— Last year we also started making
contributions for monies collected by Payplan and we expect to
contribute around £350,000 per annum in this way.
6.2. We also have a leaflet available in
branch, `Help with Financial Difficulties', which provides
advice, guidance and support for customers who experience problems
with their finances. A copy is enclosed for information.
6.3. We work closely with local Citizens'
Advice Bureaux in order to discuss issues of concern on policy
and practice as they arise. The Lloyds TSB Foundations has also
provided over £130,000 of funding to Citizens' Advice Bureaux
in the last two years.
Financial education
6.4. Lloyds TSB is fully engaged in the
work of the FSA's Financial Capability Steering Group and Eric
Stobart, Director of Public Policy & Regulation, Lloyds TSB
Group, chairs the Workplace Working Group, supported by Jim Dredge,
from Lloyds TSB as a full time Programme Director for this initiative.
6.5. The workplace presents one of the most
appropriate places for developing improved financial capability
as it is one of the few places where adults can be reached, with
scale. Additionally, as many employees now take home a `package'
rather than a simple wage or salary, financial educational messages
can also reinforce the remuneration package explanation and the
components that comprise it (eg Pensions). Individuals generally
show a higher level of trust for their employer, than for either
Government or the Financial Services Industry, so this partnership
in the workplace is seen as a good delivery channel for education.
6.6. Activity In the workplace is particularly
targeted at employees in the first half of their working lives,
who also earn less than the national average income. We see the
financial services industry, in partnership with Government, having
a key responsibility in this sector. However, to be really successful,
this education needs to build on skills learned by children at
school, and young adults within further education, and it is in
these areas that we believe Government has a primary responsibility.
We were very encouraged by the Chancellor's recent Pre Budget
Report announcement about adding financial education to the curriculum
from 2008.
6.7. The Workplace Working Group has conducted
a series of pilot studies, focusing initially on large employers
in the public and private sector, to test what can be achieved
in practice and what tools work most effectively in this environment.
The large companies that are involved alongside Lloyds TSB are
Stagecoach, Centrica, Heart of England NHS Trust and Scottish
Power. Plans are underway for a significant scaling up of activity
in 2006-7 and beyond.
6.8. The employees of the participating
firm all receive paper based information covering financial literacy,
and this is built on with the provision of workplace educational
seminars, which cover budgeting, planning, borrowing, savings,
investment and link to the firms employee benefits. The seminar
is supported with material that help the employee carry out risk
based assessments of their financial situation, and help put them
in control of their money.
6.9. Feedback on the results of the pilots
so far has been encouraging from unions, employers, presenters
and employees and they are helping develop our plans going forward.
This is a true partnership and we see this as a requisite component
of success in improving financial education through the workplace.
6.10. Experience to date has shown that
it is easier to access employees in firms employing 500 or more
staff in the private sector. More work needs to be undertaken
to understand how to effectively deliver effective financial education
to around 50% of employees who are working within smaller firms
and the around 20% of the workforce employed within the public
sector. In the latter, HM Government could really help drive the
agenda forward, acting as a partner with advocacy from an "employer"
perspective.
7. INCENTIVES
AND BARRIERS
TO SAVING
FOR PEOPLE
ON BELOW
AVERAGE INCOMES
7.1. There are four key issues that should
be addressed by Government when encouraging people on low incomes
to save:
a. Clarity on which customers we are targeting.
b. A regulatory environment that makes products
simple and cost effective to sell.
c. Better education to raise awareness of
the need to save from a very early stage and the solutions available.
d. Clear incentives that encourage long term
savings.
7.2. It is important to bear in mind that
people with lower incomes are sometimes discouraged from saving
where, for example, the amount they save impacts on the Government
benefits they receive. The current system of incentives and benefits
is highly complex and clearer incentives that people understand
and that encourage additional saving would be welcome. One simple
area where additional saving could be encouraged would be to ring
fence savings through ISAs from any means testing in later years.
This would send a clear message encouraging people to save for
the longer term.
7.3. Lower earners with debt should also
be encouraged to pay this off before saving as the interest they
are incurring is likely to exceed the potential growth on low
risk products.
7.4. In addition, our own research shows
that there are many people who are able to save, but choose not
to either through dis-interest or simply because they would rather
spend any free income on living for today.
7.5. Banks have a role to play in ensuring
that products are available for individuals on a low income. Lloyds
TSB supports initiatives such as the Government's Child Trust
Fund scheme. We have teamed up with the Children's Mutual to offer
the Baby Bond® Stakeholder Child Trust Fund account. We have
opened over 50,000 accounts, however, only around 20% of these
have been topped up by direct debits and cheques.
8. THE ROLE
OF THE
GOVERNMENT, THE
FSA AND OTHER
BODIES AND
ORGANISATIONS IN
PROMOTING FINANCIAL
INCLUSION
8.1. As providers of financial services,
banks need to ensure that their products and services are transparent
and accessible to all consumers. There are, however, people from
certain sections of society who do not wish to have a bank account,
or who, for a variety of reasons, might prefer to use alternative
sources of credit. There will therefore, always be some individuals
who choose to remain `unbanked' and it is for other organisations,
such as Government and organisations involved in initiatives such
as the Community Banking Partnerships (CBP) which we support,
to address these areas.
8.2. When government automated benefits
it gave benefit recipients a choice between a basic bank account
and a Post Office Card Account (POCA). Four million people made
that choice and opted for the POCA. As highlighted in a Written
Question from Lorely Burt, MP on 9 January 2006, it is disappointing
that the limited functionality of these accounts means that they
are not suitable for receiving payments of housing benefit or
the local housing allowance. In addition, we understand that Government
does not consider people with these accounts to be "banked".
One option for Government might, therefore, have been to sanction
the addition of greater functionality for the POCA to allow direct
debits and standing orders. However, we understand that Government
intends to end the contract for the POCA in 2010, which will mean
that the four million people who opted for a POCA will have to
make alternative arrangements to receive their benefits.
9. THE BENEFITS
OF FINANCIAL
INCLUSION AND
THE EXTENT
TO WHICH
FINANCIAL INCLUSION
MEASURES CAN
CONTRIBUTE TO
COMBATING POVERTY
AND REDUCING
BARRIERS TO
EMPLOYMENT
9.1. Current financial inclusion measures
such as the provision of basic bank accounts and other initiatives
can only go so far in combating poverty and reducing barriers
to employment. Other organisations also have an important role
to play. The National Consumers Council has, for example, recently
called for changes to basic bank accounts to allow weekly direct
debits to enable people on very low incomes to budget on a weekly
basis. All bank accounts, in the main, currently have that functionality,
however, the onus is on the direct debit initiators, for example,
the utility companies and other retailers to amend their systems
and provide this service to their customers. Accessibility and
transparency, therefore, goes wider than just the financial services
sector.
9.2. With the Automated Credit Transfer
(ACT) of Government benefits now complete, it is widely acknowledged
that banks have collectively fulfilled their commitments in the
"supply" of basic bank accounts. What now needs to be
understood is the demand from those people in society who remain
"unbanked" and Government is best placed to conduct
research into the reasons why individuals prefer not to hold basic
bank accounts.
January 2006
180 * Post Office Press Release, 18 July 2005. Back
181
Millward Brown, BBA Inclusion Research, 8 November 2005. Back
182
City Research Series, No. 6 commissioned by the Corporation of
London, June 2005-`Anti money laundering requirements: costs,
benefits and perceptions'. Back
183
BBA Press Release, Non Plastic Related Fraud Increases,
11/03/2005. Back
184
Change is a London-wide initiative that was launched in January
2003 in partnership with London & Quadrant Housing Trust (one
of London's largest social landlords). Pilots were launched in
several boroughs covering the promotion of credit union membership,
financial education and debt advice. Back
185
Forrester Consumer Technographics, 2001-2004. Back
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