120.The Committee has previously raised concerns that financial services providers are not complying with the Equality Act in the provision of reasonable adjustments, including providing information on how to access information in different formats on all consumer correspondence, including marketing material.
121.The Equality Act 2010 requires service providers to make reasonable adjustments for individuals covered by the Act. Section 20 of the Act requires that where a provision [of a service] puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, a provider of that service must take such steps as are reasonable to avoid the disadvantage. Section 20 (7) states that the provider of a service is not “entitled to require a disabled person to pay to any extent of the provider’s costs of complying with the duty”. Section 29 of the Act states that: “a service-provider concerned with the provision of a service to the public must not discriminate against a person requiring the service by not providing the person with the service”.
122.In oral evidence, Eleanor Southwood, Chair of the Royal National Institute of Blind People, made it clear that the regulators should be using their “teeth” to enforce the Equality Act:
We welcome the focus on best practice and so on, but actually the FCA does have considerable powers in terms of standards. We are not talking about standards that are nice to have and gold-plated services. This is about whether you can see how much money you have in the bank and make your own financial decisions. We would very much like to see them use the teeth that they have to a greater extent. It is great to remind the regulated firms that they have a responsibility, but we do have equality legislation. There is a duty. This is absolutely the realm we are in.
Similarly, on the work of the Equality and Human Rights Commission. It is a bit carrot and stick, I think. Of course, enforcement, probably through the FCA, is really, really important, but so is helping banks to understand what the solutions might be. We really want to see all financial institutions working increasingly with organisations like those the three of us are representing today to get it right first time. Updates are constant on websites. This is not something that a bank will do once every five years; this is an everyday event and everyday responsibility.
123.The Equality and Human Rights Commission (EHRC) website states that it is:
The regulatory body responsible for enforcing the Equality Act 2010 […] we also have a range of enforcement powers […] They range from guidance and assistance to investigations and court action. […] We only use our legal or enforcement powers when it is the best way to achieve change, such as:
To do this, we use the courts and tribunals to secure binding, positive judgments that reinforce, strengthen or expand people’s rights.
124.However, Andy Goldsby, Community and Partnership Manager at the Equality Advisory Support Service (EASS), explained that in order to force a company to comply with the Equality Act, that person as an individual needs to take the company to court:
The Act itself empowers the individual to take a complaint. In this situation, if it is access to services, that would be to county court, or sheriff court in Scotland.
125.The Committee asked Rebecca Hilsenrath, Chief Executive of the EHRC, whether enough was being done to ensure that reasonable adjustments were being made for customers who may not be able to complain about their ability to engage with the bank. She told the Committee that in its strategic plan the EHRC was “looking at a very small number of strategic priorities, and they would not be focusing on financial services.” Such issues were not a “strategic priority” of the EHRC.
126.When the Committee took evidence from the EHRC, FCA and the EASS, it was unclear which of the statutory bodies was taking active responsibility for dealing with issues raised by the public, and which was responsible for enforcing the Equality Act when breaches of the Act occurred. Rebecca Hilsenrath told the Committee that a member of the public should “complain to the Equality Advisory Support Service”.
127.However, Andy Goldsby of the EASS argued that it was not responsible for enforcing the Act, and only provided assistance:
The remit of the EASS is initially to give advice to individuals who have experienced discrimination, not just with access to services, but in all areas that the Equality Act covers. […] We would give them advice about the rights they are likely to have, so in particular we would make reference to the reasonable adjustment duty, and then set them on their way with an initial action plan. We have things like template letters that are available to individuals on our website. If an individual would struggle to communicate with the organisation, we are likely to do that for them, but at an informal stage. […] We cannot enforce compliance at all.
128.In a letter to the Committee the FCA wrote that it, too, was not responsible for enforcing the Equality Act:
The FCA does not have a direct role to enforce the Equality Act 2010, this is the role of the EHRC. […] We would not, for example, normally expect to use our rule-making, supervisory or enforcement powers to set standards in respect of, or to address, equalities issues, except where the conduct of a firm called into question whether consumers had been treated fairly under our rules. Whether individuals had been discriminated against under the Equality Act 2010 as a result of their protected characteristics, would, therefore, be a matter for the EHRC.
129.The FCA letter went on to say that the Equality Act can inform the Financial Ombudsman’s investigations, but that it was not responsible for enforcing the Act:
The Financial Ombudsman Service (FOS) is in place to resolve disputed complaints between consumers and financial services firms. The FOS is required to do so by considering what is “fair and reasonable” in all the circumstances. In doing so, it must take account of a number of factors, including relevant law. This could include the Equality Act 2010. The FOS maybe able to award “fair compensation” if it considers the firm has not acted fairly and reasonably. However, it is not the FOS’s role to determine legal liability. As such, it is not the FOS’s role to make a finding of discrimination under the Equality Act 2010.
130.In a letter to the Committee, Caroline Wayman, the Financial Ombudsman wrote:
In accordance with the legislation and rules, the Ombudsman would be making a decision on what is fair and reasonable in all the circumstances of a complaint. It is not for the Ombudsman to make a formal finding the Act is engaged or has been breached. Findings on matters of law are reserved for the courts. […] If we had concerns following on from individual cases then we would be likely to contact the Financial Conduct Authority or the EHRC, but we do not take cases to court on a consumer’s behalf if they are looking to get a formal ruling from a court that the Equality Act has been breached.
131.The EHRC is the statutory body for enforcing the Equality Act and has statutory powers for doing so. However, it has confirmed to the Committee that it does not have the relevant resources or expertise to investigate each individual case where a financial services provider is potentially in breach of the Equality Act, or is failing to provide reasonable adjustments, and that therefore such issues were not one of its strategic priorities. At present, no other statutory body has the power to enforce the Equality Act. As a result, the only recourse available to individual consumers is to take financial services providers to court themselves. This is unacceptable. To expect vulnerable individuals to be able to take their financial services provider to court in order to enforce their rights under the Equality Act is absurd. Taking a high street bank to court would be prohibitively expensive and daunting for an individual. Given the FCA told the Committee it does have the expertise and resources, the Government should give the FCA the power to take on the enforcement of individual cases relating to financial firms’ compliance with the Equality Act, in addition to the EHRC.
132.The Committee asked Rebecca Hilsenrath how the EHRC define a reasonable adjustment. She explained that the EHRC does not define what a reasonable adjustment should be:
It is less about how I would define it but, in any one circumstance, it is ultimately about how the courts would define it. In relation to financial services and a reasonable adjustment that needs to be made for a disabled customer, the court would look at all the surrounding circumstances. They would be a combination of the needs of the customer and the disadvantage they might encounter if it were not made, against the disruption to the business, the cost of it and so on and so forth.
She also explained that the Equality Act requires companies to anticipate what consumers may need in advance, rather than acting retrospectively:
Reasonable adjustments are an anticipatory duty, so it is about financial services being aware of those needs and putting adjustments into effect in advance.
133.The Committee considered a number of areas where some parts of the financial services industry were failing to provide reasonable adjustments and areas where adjustments were necessary.
134.At the Committee’s outreach event in Newcastle the Committee received evidence that translation services, interpreters, or British Sign Language (BSL) interpreters were not available from all financial services providers. In addition, many financial services providers would not talk to friends and family owing to concerns that the consumer may be under duress.
135.When the Committee took evidence from financial services providers, Robin Bulloch, Managing Director, Lloyds Bank and Bank of Scotland Retail, confirmed that Lloyds Bank did offer interpreters and facilities to communicate in BSL in online video conversations:
As you would expect, we have induction loops in all our branches. Much of the content is online and we have signers’ video content to convey the key elements of the information. If a customer wishes to have a discussion in one of our branches using a signer, they can either bring somebody in who can work with them and communicate with us, or we will provide a signer and cover the costs, up to £200, for the provision of a signer. There is absolutely access that way.
[…] Where the customer has indicated that they are vulnerable or we have entered into a discussion with them around a perception of their vulnerability, we can record support needs. One example of that is if the customer needs support through the use of a signer or they need longer meetings. If they contact one of our centres and go through the standard verification, we are happy to have a family member or friend speak to us on their behalf.
136.The evidence gathered at the Committee outreach event in Newcastle suggested that even if services such as the use of interpreters were available, often staff in branches were not aware of it, and customers were not made widely aware of it.
137.Andy Goldsby told the Committee that the cost of providing BSL interpreters was prohibitive for service providers across a number of industries:
This issue does not just affect the financial services industry. For people booking appointments to see an optician or interacting with their GP, the element it always comes back to when it comes to BSL interpretation is that it is cost-prohibitive to provide an interpreter. People try to rely on the “reasonable” element of the adjustment duty to say that it is not reasonable because it is too expensive. That is our experience from the types of calls we are getting, so it is not just financial services; it seems to be across the board.
138.Rebecca Hilsenrath told the Committee the EHRC would expect banks to provide a foreign language interpreter or a BSL interpreter, but did not want to be prescriptive:
I would expect a bank or financial services provider to ensure that, in designing their services and systems, they include those who are hard of hearing in their consultation processes and design their processes around that. [ … ] As well as the needs of the individual customer, it also depends on the size of the institution. How big is the bank? What are its other obligations? What are its resources and what is its customer profile? I would expect a reasonable and conscientious bank to know all that information and ensure that it had it.
139.The Committee is of the view that providing British Sign Language interpreters—with notice—should be considered as a reasonable adjustment under the Equality Act and therefore non-compliance should be enforced by the Equality and Human Rights Commission. The argument that providing British Sign Language could only be classed as reasonable in the context of the size of a firm would excuse smaller firms from providing services to people with hearing loss.
140.Financial services providers should act immediately to ensure that with notice, interpretation services are made available to consumers, both for British Sign Language users and those for whom English is not their first language, as a matter of urgency. Firms must also make more effort to alert customers to the existence of such services, and how they can access them, and ensure that staff in all branches are aware of the existence of these services. The FCA should make it clear to financial services providers that such provision is expected of them under its treating customers fairly principle. This requirement would be even more explicit if firms had a legal duty of care to their customers.
141.In oral evidence sessions (as well as the outreach work undertaken by the Committee in London and Newcastle) the issue of talking ATMs was raised. Eleanor Southwood, Chair, Royal National Institute of Blind People (RNIB), told the Committee about the difficulties for visually impaired people of dealing with ATMs and chip and PIN machines:
The frustrations people have with arriving at an ATM and finding that it does not speak are enormous. They also use headphone jacks, which are 3.5mm jacks, which most mobile phones are now phasing out. Also, of course, digital [touchscreen] cashpoints are coming in. People are anxious about how they will get their money when it is all [touchscreen], and how they will pay for things when chip and PIN is also touchscreen. That is a huge concern. […] It is a challenge, if you cannot see, to be faced with a new and different machine every time you go to pay for something. It is even worse if you cannot put in the numbers independently. We are profoundly disappointed with the lack of engagement by the industry and manufacturers on this issue.
She went on to relate an example of how this had affected her personally:
The other day I got into a taxi and had to pay on my card. It was a touchscreen. I just had to give the driver my PIN. That is a deeply unsatisfactory arrangement. Why on earth should somebody who cannot see be putting themselves at that level of risk of financial crime, just because it is not accessible? That is a huge area of concern.
142.In correspondence LINK told the Committee that out of the 63,000 ATMs in the LINK network, only around 17,000 provide audio assistance.
143.Eleanor Southwood also raised the issue of tactile credit or debit cards and paper money:
The RNIB worked directly with the Bank of England on the new notes. I know there is a mixed view out there about the notes themselves, but the tactile markings on the notes have been incredibly positively received. It is much easier now to identify what money you have. Cards are a bit more of a mixed bag. Flat cards are starting to arrive. That poses a challenge for people who use the tactile markings to be able know which way in the cash machine to put the card, for example, whether it is your store card, your Boots Advantage card or your credit card.
144.A further issue for blind or partially sighted people was the use of chip and signature cards. Eleanor Southwood told the Committee such machines had not been rolled out to all Post Offices:
Often, people are signposted to the Post Office. Lots of, particularly older, blind and partially sighted people prefer to use a chip and signature card. You cannot do that in the Post Office, because the transaction is closer to buying something, rather than a financial transaction, if you like. Again, you find that people are excluded.
145.The Pay Your Way website, a campaign run by Payments UK, a body representing the payments industry, states that chip and signature cards should be accepted everywhere:
Retailers who take card payments are obliged to accept chip and signature cards. The 2010 Equality Act has reinforced the legal responsibility for all businesses to cater for disabled customers—and this includes accepting a chip and signature card. In addition, Visa and MasterCard have rules in place that require retailers to accept all genuine transactions that are made using their branded cards. Every PIN terminal is designed to accept chip and signature—simply put the card into the PIN terminal and the retailer will be automatically prompted to ask for your signature. If you encounter a shop that says they don’t accept it, ask them to insert the card and follow the prompts. Your card should never be rejected simply because it is chip and signature.
146.The European Accessibility Act , an EU Directive, was approved in the European Parliament on 13 March 2019 and will come into force once adopted by the Council of Ministers. Section I of Annex 1 to the Directive prescribes that products that “provide communication, including interpersonal communication, operation, information, control and orientation, shall do so via more than one sensory channel; this shall include providing alternatives to vision, auditory, speech and tactile elements.”
147.The Committee is concerned that almost three quarters of ATMs do not offer audio assistance. ATMs that do not have the capability to “talk” or ATMs that have a touch screen rather than physical buttons with Braille, are not accessible for visually impaired consumers. It is concerning that the RNIB (and other charities representing disabled people) have not been consulted on the roll-out of this new generation of ATMs. The European Union Accessibility Act which is due to come into force in April 2019 sets out what is required from ATMs to make them accessible. Given the UK Equality Act creates an anticipatory duty on providers to implement reasonable adjustments for consumers, the Committee expects ATM manufacturers and providers to make the adjustments set out in the EU Accessibility Act, irrespective of whether the UK remains in the EU while this Act is implemented. The Committee expects the Payment Systems Regulator to set out in response to this report whether it will mandate firms to do so.
148.The roll out of credit and debit cards that are not tactile, and therefore offer no way for visually-impaired consumers to tell which way round they need to be inserted into ATMs, is a backward step by financial services providers. The Committee recommends that the FCA should mandate that all debit and credit cards have tactile markings as soon as possible.
149.The roll out of touchscreen chip and PIN pads, which cannot be used by blind or partially-sighted customers, is another backward step by the payment infrastructure industry for those who rely on tactile buttons. It is unacceptable that partially-sighted customers might have to tell vendors their PIN in order to be able to pay with chip and PIN. As with ATMs, the European Accessibility Act sets out what is required to make payment terminals accessible. The Committee expects payment terminal manufacturers and providers to make the adjustments set out in the EU Accessibility Act. The Committee expects the Payment Systems Regulator to set out in response to this report whether this will be done.
150.If the Post Office is to be used as a cash provider of last resort in communities where all other ATMs and bank branches have been closed, it must offer chip and signature in every Post Office branch in order to meet its obligations under the Equality Act to provide customers with reasonable adjustments.
151.At outreach sessions in London and Newcastle, the Committee heard that it is important for all consumers to have the ability to communicate with financial services providers. In written evidence, the Financial Services Consumer Panel described the standard method of bank communication:
Banks can sometimes ask customers about their communication needs (often with a limited range of options such as braille) but rarely ask about their communication preferences. If a wider range of options was available to all customers (including email), this would enable vulnerable customers to choose their preferred communications channel without stigma.
Those with mental health difficulties have specific communication needs ranging from the need to see a financial professional face-to-face, to not being able to speak to someone in person at all. With the increase of bank branch closures, clearly some of the most vulnerable will struggle to access financial services independently.
152.Similarly, the Money and Mental Health Policy Institute provided written evidence to the Committee explaining that people with mental health problems can find certain communication channels difficult to engage with:
People with mental health problems often experience difficulties communicating in certain ways. Three quarters of people who have experienced mental health problems find at least one common communication channel distressing or difficult to engage with. Some are phobic about using the telephone, opening letters or face-to-face contact with firms. Others need the reassurance of a real person and may not trust chatbots or even webchats with human operators. These difficulties can prevent people from receiving information, and can quickly lead to missed payments and other problems.
153.Eleanor Southwood highlighted two issues where blind or partially sighted consumers experience difficulty when trying to receive accessible communications:
The first is access to information. That is about getting your bank statements in a format that you can read. It is also about being able to communicate to the bank in the way that works for you. It is about making sure there is a consistent service across different products in one bank. We certainly know of examples where everything to do with your current account is absolutely fine, but if you go for a mortgage, suddenly you do not have that consistency of accessibility. [… Another] area is around websites, apps, the ways information is presented and the ways you can interact with it. We are still retrofitting accessibility to websites. Very often, a website update will be a downgrade as far as our community is concerned. You have to learn it all over again. If a website is not accessible, that drives you to your local branch, and we know that branch closures are a major concern too.
154.In a letter to the Committee, Christopher Woolard, Executive Director of Strategy and Competition, FCA, confirmed that the FCA was not going to prescribe how firms communicate with vulnerable customers:
Our forthcoming vulnerability guidance, on which we plan to consult this year, will clarify how we expect firms to treat vulnerable consumers, including guidance on how to comply with Principle 7 of our Principles for Businesses, which states that firms must pay due regard to the information needs of their clients. We would not however set standards or provide guidance on how firms should communicate with customers in order to meet their obligations under the Equality Act 2010, for example, whether particular formats or channels of communication must be made available. These are matters that are generally beyond our role and expertise as a financial services regulator, and where other bodies, such as the EHRC and EASS would be better placed to act.
However, as explained earlier in this Report, the EASS is not responsible for providing guidance or issuing opinions on compliance with the Equality Act or enforcing companies’ compliance with the Equality Act.
155.When the Committee asked Christopher Woolard why the FCA was choosing not to set standards or guidance on how firms communicate with customers, he said the FCA was trying to focus on the culture of firms towards vulnerable people rather than being prescriptive:
[The FCA] takes a very broad view of what constitutes vulnerability. In that set of circumstances, there is a practical limit to where we could set out, in very clear binding rules or guidance, exactly what you should do in every single circumstance. Many [vulnerable customers] will have very individual circumstances, and we are trying, with our own focus on vulnerability, to create a culture in which we set an expectation for firms in which they have to think about this. They have to apply some basic principles and thinking here, then say how this plays out in the circumstances of the individual customer in front of them.
156.The Equality Act requires companies to take “steps for ensuring that in the circumstances concerned the information is provided in an accessible format”. The Committee has received evidence that some firms do not provide information on their correspondence to enable customers to request accessible formats of the correspondence. Annex I to this report includes an example of a leaflet published by Halifax that includes information to how customers can request the information in a variety of alternative formats.
157.Section III of Annex 1 to the European Accessibility Act prescribes “The provision of services in order to maximise their foreseeable use by persons with disabilities, shall be achieved by:
(i) making the information available via more than one sensory channel;
(ii) presenting the information in an understandable way;
(iii) presenting the information to users in ways they can perceive;
(iv) making the information content available in text formats that can be used to generate alternative assistive formats to be presented in different ways by the users and via more than one sensory channel;
(v) presenting in fonts of adequate size and suitable shape, taking into account foreseeable conditions of use and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs;
(vi) supplementing any non-textual content with an alternative presentation of that content; and
(vii) providing electronic information needed in the provision of the service in a consistent and adequate way by making it perceivable, operable, understandable and robust;
158.As set out in more detail in paragraph 181 of this report, The Money and Mental Health Policy Institute told the Committee that using a universal design approach would prevent many issues around accessible communications in the first place:
By ensuring that communications are accessible, even to those with particular problems understanding, regulators can reduce harm for those with mental health problems and benefit consumers more broadly with simpler information.
159.If firms designed their communications in the first instance to be accessible to all customers using a universal design approach, many of the difficulties faced by vulnerable consumers as a result of inaccessible communication from their financial services provider would be removed.
160.All financial services providers should ask customers proactively what their preferred method of communication is and ensure that this is the primary way with which they are communicated in every instance. In addition, providers should make themselves aware of consumers’ changing preferences over time.
161.The Committee recommends that the FCA acts to ensure that alternative methods of communication including Braille and Moon tactile fonts, large print and audio format are made available to consumers. In addition, the way in which to access these methods should be made clear, in large print, on all communications, including marketing material and terms and conditions.
162.The Committee is concerned that the FCA has not chosen to set standards or issue guidance, and is instead relying on a principles-based approach to require firms to provide their customers with the communication channels they are entitled to by law. A principles-based approach, with no active enforcement, will not deliver the outcomes that vulnerable or disabled customers need. When its guidance is published, the FCA should set a minimum level of communication channels or methods that firms are required to offer to their customers, and include a clear requirement for firms to provide information in all the formats set out in paragraph 161.
163.The European Union Accessibility Act will set standards of how accessible banking providers’ websites will need to be. Irrespective of the UK’s relationship with the EU, the Committee expects financial services providers in the UK to, at a minimum, meet the requirements set out in the Accessibility Act. The Committee expects the FCA to monitor compliance of firms with these requirements, and to work in regular collaboration with relevant organisations such as the Royal National Institute of Blind People to ensure that firms continue to meet legal requirements in the future, and that as new issues arise, the FCA is made aware of them.
164.If the EHRC or the FCA is unable to enforce the provision of marketing or direct communication materials in accessible formats through the Equality Act, the Committee recommends that the Government amends the Equality Act to put in place a legal obligation on financial services providers to provide alternative methods of communication including Braille and Moon tactile font, large print and audio format for consumers, and give powers to the FCA to enforce such a regulation.
165.The National Literacy Trust state that 7 million people can be described as having ‘very poor literacy skills’. For such people, reading terms and conditions and other communications from financial services providers can be extremely challenging. Fair by Design, a campaign to raise awareness for the higher costs of services for people on lower incomes, submitted evidence to the Committee with examples of how customers found it hard to understand the information their bank was providing them:
Lucy: “I have often felt confused by the way my bank communicates to me. At the ATM they say you’ve got this amount but the amount you’ve got to spend is different. It can be confusing. They don’t write pending [transactions]. I need to see it black and white on the screen.”
Sarah: “Sometimes I wish they would write simpler. Not a lot of people have someone else in the house to help with understanding the words they use, say on bank statements. Like Elderly people. Or people with [learning] difficulties. Even teenagers often don’t understand.”
166.The Committee did receive evidence that financial services providers have already changed terms and conditions to make them simpler to understand. When giving evidence to the Committee, Robin Bulloch told the Committee that Lloyds was working on improving the clarity of their communications with customers but it was not a simple task:
We recognise that much of the literature we provide, largely driven by regulation and other factors, is quite complex. We have a major programme underway; we have 40 people looking at this in the plain English team. They are looking to reduce the reading age of all the material from the bank from an average of 18 and above to 11.
167.Tom Blomfield, Chief Executive and founder of Monzo, a smaller start up bank, told the Committee:
We work very hard to ensure that all our written content is as accessible as possible, so we have a Clear & Simple Mark by Fairer Finance. Our terms and conditions are under 1,000 words, with a reading age of eight, so we have worked very hard there.
168.Christopher Woolard told the Committee that the average level of literacy in the UK is that of an 11 or 12 year old, which implies an understanding of basic percentages and fractions. However, he told Committee the complexity of the concepts involved in banking was only one part of the problem, the length of terms and conditions was another:
There is a much broader question around the complexity generally of terms and conditions, as well as sometimes the way in which products are presented and sold.
He also told the Committee the FCA had undertaken an exercise to see how much text was actually required in a firm’s terms and conditions:
We sat down with their current account terms and conditions and that document was the size of Charles Dickens’ A Christmas Carol. At the end, you sign and say, “I have understood all of these terms and conditions”. When we went through it, a side and a half of A4 in normal type were regulatory requirements. The rest of it had all been put in by successive generations of general counsel at that firm, and no one had ever had an incentive to take words away.
169.The Committee welcomes the spirit of the efforts made by financial services providers who have begun to simplify and reduce the length of their terms and conditions. However, significant further steps are required to ensure that communications are accessible to all customers. The Committee recommends that all financial services providers reduce the length of their terms and conditions, and reduce the required reading age of all their communication material to that of the average reader, which the FCA told the Committee is that expected of an 11 to 12 year old.
170.The Committee recommends that the FCA issues guidance to all financial services providers instructing them to ensure that all their communications with their customers—especially terms and conditions—are written in language that an average consumer can read and understand in full. The FCA should consider reviewing progress made by firms on simplifying their terms and conditions on a regular basis. The Committee will monitor FCA progress on this matter in future evidence sessions.
109 from Lord Tyrie, former Chair of the Treasury Committee, to Andrew Bailey, Chief Executive of the FCA, 31 October 2016, from Rt Hon. Nicky Morgan MP, Chair of the Treasury Committee, to Andrew Bailey, 28 March 2018
110 Equality Act 2010, Part 2,
111 Equality Act 2010, Part 3,
113 Equalities and Human Rights Commission, , accessed 8 April 2019
120 Financial Conduct Authority ()
121 Financial Conduct Authority ()
122 from Caroline Wayman, Chief Ombudsman, to Rt Hon. Nicky Morgan MP, Chair of the Treasury Committee, 18 March 2019
127 Treasury Committee ()
134 Office of the Public Guardian
137 Pay Your Way, ‘’, accessed on 8 April 2019
138 Formally known as The Directive of the European Parliament and of the Council on the accessibility requirements for products and services
139 Annex 1 of the Act Directive (EU) 2019/… of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services
141 Financial Services Consumer Panel () para 26
143 Financial Conduct Authority ()
144 See paragraph 121
146 Equality Act 2010,
147 The European Accessibility Act Annex I
148 Money and Mental Health Policy Institute () page 5
149 National Literacy Trust, , accessed on 8 April 2019
Published: 13 May 2019