The Impact of Bank Closures on Adults with Dyslexia: Are the FCA’s Vulnerability Policies Enough?
This week, in my own town, I have seen that 2 banks will close their branches by the summer. As many readers will know, my dad is dyslexic and I fear how this will impact upon him.
In recent years, the UK banking landscape has undergone a seismic shift. According to data from Which?, a total of 410 branches were closed or scheduled for closure during 2024. This includes closures from major banks such as Barclays (90 branches), Lloyds (83), Halifax (76), NatWest (68), Bank of Scotland (31), TSB (28), RBS (20), Ulster Bank (10), and Danske Bank (4).
Since 2015, more than 5,700 bank branches have closed across the UK, with 645 of those closures occurring in 2023. The trend continued in 2024, with nearly 200 additional closures announced.
With the rise of digital banking and the closure of thousands of high street branches, millions of customers have had to adapt to a new way of managing their finances. For adults with dyslexia, this transformation presents unique challenges, raising the question: has the Financial Conduct Authority (FCA) done enough to support this group under its vulnerability framework?
Dyslexia and Banking: A Complicated Relationship
Dyslexia affects approximately 1 in 10 people in the UK, impacting their ability to process written information. In fact, approximately 23% of adults in the UK have literacy difficulties. This equates to roughly 9 million adults. These means accessing information from financial institutions can be very difficult, added to this there is a lot of financial terminology to try and decode. For many of us, even with out literacy difficulties, it can be hard work trawling through terms and conditions and processing the language.
This condition can make navigating financial documents, online platforms, and complex terms and conditions particularly challenging. For those who relied on high street branches to conduct their banking in person, the closures are not just an inconvenience but a significant barrier to financial inclusion.
Face-to-face interactions often provide a level of clarity and reassurance for adults with dyslexia. Many people use their local bank and often staff would get to know the level of support an individual may need. Bank staff can explain products verbally, guide customers through forms, and provide immediate answers to questions. With the shift to digital banking, these services are increasingly being replaced by automated systems and online chatbots, which are not always designed with accessibility in mind.
This week, I have tried to set up 2 bank accounts, I was forced to do this on an app, as the branches were closed in my town. Both of which required me to search for long periods for information in general and then to find contact details or the call centre. When I contacted the call centres, I was then given conflicting information to what I had read on the app or their website. I find when contacting any call centre, having to listen and process and retain which option to choose (if there is one that meets your question) is very difficult. Dyslexia can go beyond reading and writing difficulties and often there are coexisting learning difference which add to difficulties. Even the process of trying to book a f2f meeting in a branch was done digitally, you simply can’t call to book an appointment. There were several pieces of information to read and make decisions about, even to get to this stage. In fact, I was furious and ready to give up. I consider myself tech savvy and literate.
Closing local branches also means that individuals will then need to travel to cities to find a branch and speak in person. Again, there is no regard for how literacy difficulties impact the capacity to travel, especially to new places. Finding the building, using public transport, reading bus timetables, organisation skills to remember the appointment are all challenges that make such a task hard work for an individual with literacy difficulties or dyslexia.
When you finally get to speak to the call centre staff, it becomes frustrating when terms and conditions are read out to you, so fast it t can be hard to process the information. There is no thought for those that require time to process language. This also the case when phoning insurance companies.
My worry is that this does not give individuals freedom to access financial information and make informed choices, worse still, this leaves them extremely vulnerable to being scammed.
I recently learned that the FCA has a policy on ‘vulnerability’. I wanted to explore who they considered was ‘vulnerable’.
The FCA’s Policy on Vulnerability: Where Does Dyslexia Fit?
The FCA has made strides in addressing customer vulnerability through its guidance, particularly its 2021 publication, “Guidance for firms on the fair treatment of vulnerable customers.” This document identifies four key drivers of vulnerability:
1. health,
2. life events,
3. financial resilience,
4. capability.
Dyslexia may fall under the “capability” category, as it can limit a person’s ability to access and understand financial information. However, when I visited the FCA website and looked for ‘dyslexia’ or ‘literacy’ I could find nothing.
The FCA explicitly expects firms to:
• Adapt communications to meet the needs of vulnerable customers, including providing information in accessible formats such as audio or simplified text.
• Train staff to recognise and support customers with cognitive or communication difficulties.
• Monitor outcomes to ensure that vulnerable customers are not at a disadvantage compared to others.
While these principles are encouraging, dyslexia is not explicitly highlighted in FCA policy documents. This omission could mean that firms are not fully aware of their obligations to this specific group, leaving gaps in support.
Are the FCA’s Measures Enough?
For adults with dyslexia, the FCA’s policies are a step in the right direction but fall short in practice. Here are three key areas where improvements could be made:
1. Digital Accessibility: Many online banking platforms remain difficult to navigate for dyslexic users. Features such as customisable fonts, text-to-speech options, and simplified layouts are still not standard across the industry. The FCA should push for stricter digital accessibility standards, ensuring that all banking platforms are designed with inclusivity in mind.
2. Navigation: Apps and websites need to be clearly laid out with built in text-to-speech to enable read aloud functions on the website and documents.
3. Call centre access: Personally, I prefer to deal with humans anyway and call centre contact numbers should be clearly visible on the front page. Booking appointments in branch should also be available through a contact number not a digital app.
4. Proactive Identification: The onus often falls on the customer to disclose their dyslexia and request support. However, this assumes that individuals are comfortable doing so and know what accommodations are available. Banks should be encouraged to adopt proactive measures, such as asking customers about their preferred communication methods and offering tailored options upfront. At least there should be an option to press a number on the keypad, if you would like specific support.
5. Preserving Human Interaction: While digital banking is the future, it should not come at the expense of human interaction. The FCA could advocate for more hybrid models, such as maintaining in-person services at community hubs or providing enhanced telephone support for vulnerable customers, including those with dyslexia. Whilst I am now aware that some towns do have a community hub, it can be difficult finding that information in the first instance. This is further compounded if you need to research this facility if you have literacy difficulties.
The Way Forward
The FCA’s recognition of vulnerability is commendable, but there is more work to be done to ensure that adults with dyslexia are not left behind in the digital banking revolution. Clearer, more explicit guidance on dyslexia, coupled with stronger enforcement of accessibility standards, would go a long way in levelling the playing field.
As banks continue to close their high street branches, the FCA must ensure that its policies are robust enough to protect all vulnerable customers, including those with dyslexia. Financial services should be accessible to everyone, regardless of their abilities, and it is up to regulators and banks alike to make this vision a reality.
