Chapter 2 - An 'essential service'—access to financial services and cash

Chapter 2An 'essential service'—access to financial services and cash

2.1While the use of cash is declining across the Australian economy, cash and faceto-face banking services remain important for many residents, organisations and businesses in regional communities.

2.2The security and flexibility of cash is of particular benefit in remote areas and during times of crisis. Businesses and organisations continue to receive and require cash, and many residents of regional Australia rely on face-to-face banking services—especially those who are vulnerable, elderly or disabled.

2.3This chapter presents evidence on:

the ongoing need for cash;

the need for face-to-face banking services;

service access issues in remote communities;

barriers to banking services in remote Indigenous communities;

limitations of Bank@Post services;

impacts of branch closures on individuals; and

impacts of branch closures on communities and businesses.

2.4The chapter ends with the committee's views and one recommendation. Further recommendations relating to cash and services are included at the end of Chapter 5.

The ongoing need for cash

2.5The use of cash has been in decline for many years. According to the Reserve Bank of Australia (RBA), the 'share of in-person transactions made with cash halved, from 32 per cent to 16 per cent, over the three years to 2022'.[1] Usage of cash is greater in regional areas than in the major cities, but regional areas have still seen usage decline from 35 per cent to 14 per cent since 2019.[2] The Commonwealth Bank of Australia (CBA) reported that pointofsale transactions using cash declined from 43 per cent of all transactions to 15percent over the previous five years, and digital transactions increased by 64per cent between 2021 and 2023.[3]

2.6CBA estimated that the continued support and distribution costs of cash are up to $400 million per year, at an average of roughly $40 per customer. This means that customers who do not use cash are subsidising those that do and, as the number of customers using cash continues to decline, cross-subsidisation of cash services increases.[4]

2.7Despite the decline, there are still consumers considered 'high-cash users' who use cash for more than 80 per cent of transactions. Most of these users are in regional areas. RBA data suggests that around one-quarter of consumers would face major inconvenience or genuine hardship if they could no longer access or use cash.[5]

2.8Mr Tim Baird, Assistant Secretary, Payments System and Financial Innovation Branch, Department of the Treasury, advised the committee that the government is 'committed to maintaining ongoing access to cash for Australian citizens when and where they need it'.[6] However, the government does not hold responsibility for the distribution of cash. Ms Merylin Coombs, Deputy Head, Note Issue Department, RBA, told the committee that although the RBA is the sole issuer of banknotes in Australia, the distribution of banknotes is up to the banks:

We have the contract with the four major banks. They subcontract the logistics of that to somebody such as the Armaguard, and it's then up to that provider to get it out there. It's not like one of the major banks says, 'I want $10 million for Kalgoorlie.' They say to us, 'I want $10 million.' … As soon as the money goes into the truck, it becomes the ownership of the commercial bank and it's up to the commercial bank as to how that gets distributed across the country.[7]

2.9In its submission, the RBA acknowledged that people in regional areas found it less convenient to access cash services than those in major cities and that consumers have had to switch to alternative service types to withdraw or deposit cash.[8]

Benefits of cash

2.10The committee heard repeatedly throughout the inquiry that there are many benefits to using cash instead of digital transactions. Witnesses and submitters talked about the flexibility, lack of fees, and ease of budgeting offered by primarily using cash.

2.11The committee heard that many customers are adversely affected by fees applied to banking transactions that take place outside of a bank branch, including while using automatic teller machines (ATMs). The Indigenous Consumer Assistance Network (ICAN) explained how easily some customers can build up fees:

On the days that Centrelink is due to be deposited, there can be a few balance checksbefore the money arrives, then several withdrawals of $20/50/100 over the course of the dayeach incurring a fee. Then an 'insufficient funds' message on the next attemptedwithdrawal will lead to a further balance check to see how much is remaining, then a finalwithdrawal to take the remaining balance. It can be $30+ in ATM fees for a single day.[9]

2.12The issue is compounded in communities where internet service is limited. If residents do not have access to online services to check their balance they can only do so at an ATM for a fee.[10] This problem has been recognised by the Australian Securities and Investments Commission (ASIC). As part of its 'Better banking for Indigenous consumers' project, the ASIC focuses on addressing harm experienced by First Nations consumers through fees on transaction accounts.[11]

2.13Fees are also an issue for retailers. Mrs Sandi Wallace, Owner of Wallace's News and Drapery, explained that she loses approximately ten per cent of net profit on electronic transactions due to fees imposed by the banks. Since the closure of the bank branch in Carnamah, Western Australia, MrsWallace noted that the volume of cash transactions has decreased by 60percent. Transactions that were previously fee-free have now been replaced by digital transactions with fees attached.[12]

2.14Submitters also expressed their preference for using cash due to its flexibility. Tasmanian Women in Agriculture told the committee that bartering and informal transacting is more common in regional areas. The lack of access to cash hampers this means of earning extra income:

Fewer income earning opportunities in regional and rural locations see households operate in the informal sector. Microbusinesses contribute to family income through roadside stalls selling excess produce, flowers, eggs, manure, and firewood. This important poverty reducing source of household income would be hampered without nearby cash handling facilities. The availability, or otherwise, of online transactions is irrelevant in these conditions.[13]

2.15The flexibility of cash is crucial to maintaining this informal means of income and, for some, to budgeting effectively. People prefer being able to see how much money they have and cannot spend what they physically do not have. Many individuals have made submissions to the committee saying that a physical representation of money makes budgeting far easier.[14]

Natural disasters and loss of power

Box 2.1 Case study—Curry Merry Muster Festival, Cloncurry

Our events in themselves are so cash reliant. People turn up, they put cash over the bar, they put cash through the food vendors—all that sort of stuff. … [O]ur ability to have electronic interactions all the time out here is not there, so we have to have cash. There was an instance recently where the power went down for seven hours and people literally didn't know what to do. There was nowhere you could buy food. There was nowhere you could buy fuel. There was no way to get water. Everyone didn't know what to do. So it puts a real emphasis on the cash issue out here, which is that we still need cash.—Mrs Janessa Bidgood, President, Curry Merry Muster Festival.[15]

2.16Inquiry participants cited natural disasters and electrical blackouts as times when access to cash is particularly critical. Security of power and internet service is crucial if making a transition to digital transactions. Blackouts are a frequent occurrence in many regional towns necessitating the use of cash, which can only be accessed over the counter at a bank branch if the power outage has shut down ATMs.[16]

2.17Natural disasters are a distressing time for people to need access to cash. Ms Coombs noted that 'people want cash to protect against uncertainty' and that during times of disaster people turn to cash.[17] Vulnerabilities are enhanced during a crisis and can leave regional businesses and individuals exposed when there is a lack of banking facilities. Business Chamber Queensland submitted that 'vulnerabilities should be considered whenassessing suitable banking alternatives' to ensure that community needs are met in times of crisis. They believe that 'alternativebanking solutions should aim to build resilience in regional economies, rather than create increased vulnerability'.[18]

2.18East Gippsland Shire Council told the committee that bank closures can deepen uncertainty and destabilisation in communities recovering from natural disasters. The Council's submission expressed that the cumulative impact of drought, fire and flood had manifested in increasing levels of family violence, homelessness, loss of identity for communities, lower levels of volunteerism, suicides, and job losses. The frustration of losing bank branches and being forced to move online when telecommunication coverage is poor throughout the region has made the community feel further isolated.[19]

2.19Regular power outages can negatively affect the economic viability of towns. Ms Susan Curley, Chairperson, Cloncurry Local Business Network, told the committee that power outages can result in loss of business for local shops if not restored quickly:

When we have a power outage or the Internet or phone linesgo out, it's not for half an hour; it's for seven hours. It's a full day gone. If you're having transactions, particularlywith people who are just visiting town, you've missed the sale. It's gone.[20]

2.20The committee also heard evidence from Mr Don McDonald, Chairman of MDH Pty Ltd, who explained that 'to pay [employee] wages on occasions we've had to get in a helicopter and fly over the tower, because the strength wasn't good enough to get out to the property'.[21]

2.21Intermittent service is a recurring issue throughout regional areas. MrAnthony Basford, Chief Executive Officer of East Gippsland Shire Council, told the committee that service simply 'drops out, it goes to 3G' and that some towns have 'battery backup now, but, previously, pretty much every night, you'd hear the generators kick in and that community would lose power at some point'.[22] When transitioning to online services, security of power is of utmost importance.

2.22Responding to questioning about how communities continue to transact when power has been cut, Mr Peter King, Chief Executive Officer, Westpac Group, told the committee that the merchant terminals can operate in an offline mode, although this still requires a bank card. Westpac has also flown cash into disaster areas to distribute to affected communities, most notably in Lismore in 2022.[23] The Australian Banking Association (ABA) also cited the work undertaken by banks during that disaster, including the provision oftemporary branches and cash-access points.[24]

2.23In recounting her experience in Mannum, South Australia, during the Murray River flooding event in December 2022, resident Ms Catherine Clemow painted a different picture to that of Mr King and the ABA. Ms Clemow told the committee that her local branch of BankSA—a subsidiary of Westpac Group—closed its doors during the disaster:

Box 2.2 Case study—BankSA closure in Mannum, December 2022

Our only bank, BankSA, closed on Friday 16th December 2022 taking Mannum's only deposit and withdrawal ATM service with them. The closure of this bank and its ATM facility coincided with the 2022 Murray River flood waters reaching the main street of Mannum and closing the only other public (withdrawal only) ATM in the town. BankSA deserted Mannum, when it was struggling the most. A clear indication, that Banks really don't care about servicing their regional customers, only servicing their own interests. The departure of the BankSA literally left Mannum and surrounding communities high and dry, once we'd dried out from the floods!—Ms Catherine Clemow, resident[25]

Cash handling and transfer

2.24The committee heard throughout the inquiry that access to cash in regional and remote communities needs to be protected. Cash is essential to the day-to-day lives of people living in these areas. The committee was told by witnesses that 'if banks can't or won't provide a mechanism for cash circulation in regional communities, then the government needs to step in and provide a suitable alternative mechanism'.[26]

2.25The cash-in-transit (CIT) industry in Australia has been in decline for a number of years. As previously discussed, the use of cash has been in decline for years and cash volumes remain below pre-COVID-19 levels without any expectation of recovery.[27] Notwithstanding this, cash remains an integral part of regional, rural and remote communities and their economies, and will continue to be so for the foreseeable future. The next section focuses on recent developments in the cash transfer sector and some of the challenges facing the industry.

The merger

2.26The two largest businesses in the CIT sector, Linfox Armaguard Pty Ltd and Prosegur Australia Holdings, merged to form a combined business on 4September 2023. At the committee's December 2023 public hearing, Mr Mick Cronin, CEO, Linfox Armaguard, reiterated the reduction in the use of cash in recent years before outlining the reasons for the merger:

Our strategic approach to this has always been that there's only enough cash now in this country for one CIT, cash in transit, provider. We took that to the [Australian Competition and Consumer Commission (ACCC)], and they clearly agreed. It was quite a lengthy process, across nine months, and we started as a combined business on 4 September. So it wasn't long ago. Now we're bringing two businesses together, which is a challenge culturally et cetera, but it allows us to rationalise the business. It's a very infrastructure-heavy business. If you look at a map of Australia and you come down from Cairns and Mackay and Townsville—they've all got two CIT branches. One would be an Armaguard and one would be a Prosegur, previously a Chubb branch. Twenty years ago that was required, but it's not required now, so all of those towns will end up with one branch in there. That's how we get a synergy benefit from coming together like this.[28]

2.27The committee were told that the merger would save approximately $55 million. Mr Cronin outlined where the benefits come from:

That's really in three main chunks: one is closing 23 branches. Another one is restructuring corporate overhead, where we end up with about 101 to 110 roles, somewhere in there, exiting the business. And the other one is ATM rationalisation, now that we've come together with Prosegur. They have a brand called Precinct, and we have a brand called atmx. Where we see those two machines next to each other around the country, we only need one of them. So there's some rationalisation in that space too.[29]

2.28As part of the ACCC agreement to the merger, the company committed to a court-enforceable undertaking with the ACCC to service all postcodes that were serviced prior to the merger occurring.[30] All existing customers must continue to be serviced regardless of size or location.

2.29The undertaking by Armaguard to continue to provide CIT services to existing customers is a three-year commitment with rules around pricing and geographical coverage.[31]

We've been monitoring the undertaking that was provided to us by Armaguard, and that has obligations on Armaguard continuing to provide those cash-in-transit services to existing customers and also if there are any new customers.[32]

2.30In its submission, made prior to the merger, Armaguard claimed that '[t]he CIT industry is no longer sustainable'.[33] As a result of the decline in cash usage, Armaguard has sustained heavy financial losses. To counter these losses Armaguard has taken measures including the shuttering of cash processing branches, resulting in further reduction of service levels to regional Australia.[34]

2.31Armaguard continued by saying that it 'understands the importance [of] the availability of cash in regional and remote Australia', however, they are not 'in the business of providing services to regional and remote Australia as a public service and benefit, in a financially unsustainable manner'.[35]

2.32Mr Cronin explained to the committee that revenues are dropping, in part, due to the undertaking to continue service provision to existing customers. If a business, including a bank branch, leaves a town, that is one less business paying for cash services, but Armaguard is obligated to continue services to the town for other businesses. Costs of service does not change but revenues do. MrCronin explained that this makes it costly to service regional areas:

We have committed to maintaining service, as we had previous to the merger, and we will continue with that. Therein lies our problem … as businesses leave, our revenue drops, but we're still going five days a week because we've given that commitment under the undertaking.

Also, because we're a route business, if you can imagine a town, a regional centre—let's just say we go to the bank five days a week, but we might go to a chemist twice a week, for example. We'll go to regional towns right across Australia based on what our customers want. But as customers pull out and as bank branches close, which is relevant for this inquiry, our costs don't change but our revenue significantly drops. And therein lies our problem as a business.[36]

The role of the RBA

2.33In addition to the ACCC's role in approving and monitoring the agreed undertaking associated with the merger, the Reserve Bank of Australia (RBA) also has an important role in the circulation of cash in the Australian economy. The RBA explained that it is responsible for:

… the wholesale banknote distribution. We're the sole issuer of banknotes, and we do take that obligation very seriously. We also have a commitment to ensure that Australians who want access to cash can have access to it.[37]

2.34The RBA sells the banknotes from its depot to the banks. It is the responsibility of the banks to arrange the distribution of cash throughout the country:

The RBA is not responsible for the retail leg, as you said. It's based on the banks, and they distribute those funds. But the RBA has committed in its corporate plan and is also working with the government as part of its strategic roadmap on payments to ensure that cash is available to those who need and want to use it.[38]

ACCC authorised collusion for CIT

2.35On 6 December 2023, in response to the financial difficulties experienced by the merged CIT entity, the ACCC granted interim authorisation to the CIT and banking sector to collude as a means to seek a pathway to a sustainable CIT industry:

The ACCC has granted interim authorisation to the Australian Banking Association (ABA), its member banks, and other relevant industry participants to discuss and develop arrangements to maintain the physical distribution of cash throughout the Australian economy.

The authorisation application follows concerns expressed by the major supplier of cash-in-transit services in Australia, Armaguard, that the industry is not sustainable in its current form.

Cash-in-transit services involve providing cash transport, management and processing services. These services are provided to banks, retailers and independent ATM operators.

This authorisation relates only to discussions and reaching in-principle agreements about an industry response to support ongoing access to cash.[39]

2.36This interim authorisation made particular reference to regional areas:

A key condition of this interim authorisation is that the ABA report on their discussions to maintain access to cash in regional and remote areas. This will be an important consideration for any future application for authorisation by the industry.[40]

2.37In this circumstance, the ACCC is of the opinion that the benefits can outweigh the costs of collusion, noting that the authorisation extended to other entities dependent on the CIT industry including post offices and retailers:

Broadly, the ACCC may grant an authorisation when it is satisfied that the public benefit from the conduct outweighs any public detriment.

In addition to ABA members, other businesses who the interim authorisation extends to are other banks (who are not ABA members), Australia Post, cash-in-transit service providers and retailers, supermarkets and other businesses who distribute and use cash in their businesses.

2.38On 20 March 2024, the ACCC officially granted authorisation for continued discussions that would otherwise constitute collusion:

The ACCC proposes to grant authorisation with conditions until 31 October 2024 to the Australian Banking Association, its member banks, and other industry participantsto engage in discussions, exchange information and reach in principle agreements regarding the development of industry responses to challenges to the sustainability of cash in transit services and access to cash. Implementation of industry responses or solutions to sustain cash-in-transit services will, if required, be the subject of a separate application for authorisation.

Interim authorisation with conditions was granted on 6 December 2023 and will remain in place until the date the ACCC's final determination comes into effect or until the ACCC decides to revoke interim authorisation. As required as a condition of the interim authorisation, the ABA will continue to provide regular reports to the ACCC about the discussions they hold and initiatives they propose and will also report on consultation it undertakes with industry stakeholders.[41]

The need for face-to-face banking services

Issues with digital banking

2.39Issues with using or transferring to digital banking services was a recurring subject in evidence received by the committee. As banking services increasingly move to digital platforms, issues of connectivity, digital literacy, and fraud awareness become more prominent. This section will examine some of these issues and how they have negatively affected individuals and communities.

2.40Australians are increasingly using online platforms to access banking services and products. According to the ABA, as of December 2022 more than two-thirds of Australians had downloaded their bank's app. Further, the major banks reported that, collectively, there are 26 million customer accounts that have accessed online services in the previous month (noting customers often have accounts with different banks).[42] Westpac advised the committee that 96 per cent of transactions made by customers were through digital channels[43] while for the National Australia Bank (NAB) this number was 93 per cent.[44]

2.41The high percentage of transactions through digital means was questioned during the inquiry. Inquiry participants argued transaction data only captures those interactions where money is going in and out of banks. Representatives of Westpac acknowledged that their transaction tracking depends on whether a person transacts using the bank and that with cash 'they might just spend it' elsewhere without the bank knowing.[45] Thus, it is possible that the volume of cash transactions outside of the banks may impact the reliability of the data on digital verses cash transactions.

2.42The committee was told that the move from cash to online banking is a deliberate policy of the banks. The Finance Sector Union (FSU) advised the committee that retail banking workers are often required to meet performance targets in migrating customers to digital banking to reduce foot traffic in branches.[46] This issue is considered in further detail in Chapter3.

Digital connectivity

2.43Lack of connectivity is a major barrier to digital engagement for many regional Australians. According to digital inclusion data gathered by the ARC Centre of Excellence for Automated Decision-Making and Society (ADMS), 23.6per cent of Australians are 'digitally excluded', with one in ten classed as 'highly excluded'.[47] Some Australians experience exclusion at higher rates than others:

Highly excluded Australians are more likely to have a disability (24.5% highly excluded), live in public housing (28.2% highly excluded), have not completed secondary school (32.5% highly excluded), or be over 75 years of age (42.3% highly excluded). The majority of those who did not complete secondary school and/or are over 75 years of age are digitally excluded.[48]

2.44Digital exclusion is also more prevalent in regional and remote Australia. In outer regional areas, 36 per cent of people experience digital exclusion and this number rises to 40.6 per cent for those in very remote areas. This means that people living in regional and remote areas are more likely to lack access to reliable connections, and face cost barriers to digital devices or data. They also typically lack confidence in using digital technologies or lack the skills to use online services effectively.[49]

Figure 2.1Rates of digital inclusion and exclusion, by remoteness

Source: ARC Centre of Excellence for Automated Decision-Making and Society, Submission 582, p. 10.

2.45The ADMS data shows that vulnerable groups, particularly in regional areas, continue to be left behind as the economy shifts to digital mediums. The replacement of face-to-face services with online alternatives requires a basic level of access, reliable connection, and the confidence to use digital sources effectively. The ADMS data shows that, for many, this is not the case.[50]

Advice and individual services

2.46A key advantage of face-to-face banking over digital banking is the ability to provide personalised and individual services. Submitters reported that services including changing PINs, opening accounts, and applying for loans are more difficult or, in some cases, impossible to undertake over the phone or online. There is a particular need for these services in regional areas where localised and specialised knowledge in agricultural lending is paramount.

2.47For many communities, the local bank branch plays a much greater role than simply being a place for deposits and withdrawals. Mrs Quinta Lahtinen, Senior Leader, Client Services, Hinchinbrook Community Support Centre, advised the committee of the importance of personal relationships with the bank when obstacles to services are encountered:

Just last week I was supporting one of my youth clients who is 15 years old. We attended the bank together to assist her to open her own bank account. This child was subjected to childhood abuse and trauma her whole life … When we attended the bank last week, we had some issues with identification because this child had a birth certificate, but she had no means to access it because it wasn't safe to attend her family home. It's true that, because of that really strong relationship we have with the staff at one of our local banks, they were able to give us that time to really explore ways that they can help support this young person to overcome those barriers. And now, successfully, she has her own bank account, which means that she has her own income from Centrelink. She's eligible, for the first time in her life, to receive an income to meet her needs. I don't believe we could have had that result by speaking with someone on the phone in Melbourne.[51]

2.48The committee heard that the uniqueness of the agricultural industry requires specialised banking knowledge that is distinct from that of the major cities. Understanding of seasonal harvests, crop rotations, and farm management are needed when considering the financial requirements of agricultural businesses. Services required include loans for purchasing necessary equipment for crop production, crop insurance, cash management services for expenses during the growing season, and farm management advice.[52]

2.49Mr Ross Girgenti, Treasurer, Hinchinbrook Community Support Centre, told the committee that he does not believe people in larger cities understand the farming business. Mr Girgenti relayed that in speaking to bank representatives over the phone 'some [bankers] haven't even heard of a harvester' and that 'farming is peaks and troughs, weather events and other activities that take place' that require people who intimately understand the industry.[53]

2.50The need for personalised services was reiterated by Ms Charlotte Wundersitz, Senior Policy Officer, Trade and Economics, National Farmers Federation, who stressed the importance of face-to-face services in times of stress:

I think it becomes challenging because for farmers it's perhaps more about looking at that loan option. And we've been talking a lot at the moment about the forecast drier conditions. If the business is under stress, there's more of a need for farmers to go into a physical branch and talk to someone in person about the state of the business and what sorts of financial needs they might have, which farmers might not always want to do over the phone.[54]

2.51For these personalised services, a bank branch plays a crucial role in serving regional areas. Mr Stephen Capello, Chief Executive Officer, Hume Bank, summarised the particular importance and role a branch can have in rural communities:

If you purely view a branch as a transaction house, when you're costing each transaction, then I think they—the ABA or the other banks—are not recognising the role of branches in small regional towns. It's much more than just a transaction. It's a place to get advice. It's a place to do complex transactions. … So the bank branch serves a much greater role in regional communities than purely bank transactions. So, even if cash transactions are declining, the other role of banks would remain sound.[55]

Fees for digital transactions

2.52Inquiry participants were concerned that while banks are actively pushing customers towards digital banking and away from cash, they continue to charge fees for using cards and digital services. Private fee-for-service ATMs charge fees for people to withdraw cash, and banks are now increasingly charging fees for over-the-counter transactions too.[56]

2.53The Australian Citizens Party argued that the banks are 'waging a war on cash', pushing consumers to conduct electronic transactions, which must 'go through the banks'. This enables banks to 'take a cut of each transaction through fees, and monetise the data'.[57]

2.54Another submitter told the committee:

… my banking costs have skyrocketed in excessive fees due to increase in having to use non-CBA atms that incur a fee for each transaction charged by CBA, yet my pitiful almost non-existent interest on savings doesn't come close to covering the excessive fees charged by the CBA when they have drastically reduced face-to-face banking and atm banking access to cash.[58]

2.55Business owners highlighted the significant impact of digital transaction fees on their businesses. Mr Kevin Bertwistle, General Manager of the Bribie Island Bowls Club, told the committee that 'for the seven months to 1 April, for the financial year, [his] transaction fees were nearly $19 000'. Mrs Suzie Stride, licensee of the Bongaree Licensed Post Office, said:

Now fees—we spoke of them before—swipe fees, payment option fees, banking fees, Visa and Mastercard fees, [Electronic Funds Transfer at Point of Sale] (EFTPOS) fees, you name it! Australians are paying billions of dollars in card and payment fees—‍‍‍scammed in plain sight. They're not part of operational costs anymore, laying the cost squarely on the consumer. The public are waking up about fees ... What services for those fees are consumers getting? We don't know; all of us would like to know. Isn't there a regulation or law under the [Australian Competition and Consumer Commission] (ACCC) act that requires businesses and corporations to offer at least one no-fee payment option?[59]

2.56Regional Development Australia explained that the cost of digital transactions 'can impede business profitability and in turn, creates increased costs to consumers', while using cash does not incur additional fees:

As an example, after 50 transactions costing just $1, the value of a digital $50 turns to zero, whereas a $50 cash note, remains as such over the course of 50transactions and beyond.[60]

2.57Isaac Regional Council noted that some EFTPOS transactions incur fees, 'depending on the provider's arrangement with the individual retailer', and these costs may fall on the consumer who has no other option. The Council recommended that:

… in towns that only have one bank or ATM, that the bank transaction fees should be removed for electronic transactions as these have become the only viable options available in some instances. Regardless the transactions fees applied by banking institutions requires careful monitoring and regulation to ensure that banks voluntarily maintain reasonable fee structures to ease the burden on rural, regional and remote customers.[61]

Scams and fraud risk

Box 2.3 Case study—Victims of scams and fraud

Every day they get these text messages from people they've never heard of, telling them they owe a bill and that they have to pay this amount. We have customers that we know have had to do these things. They've been forced online to use digital transactions. One particular customer at an outlet was forced to digitally make a $400 000 deposit on a home and was caught up in an invoice scam. That went off to someone else, not the proper recipient of that, because this guy was having to do this digitally. And, because of all this—and it's in the news—they come to us. They know our faces. They know who we are. They feel comfortable doing these banking transactions. These people don't have enormous resources. They count every cent and every dollar.—Mr Scott Etherington, Chair, Licensed Post Office Group.[62]

2.58ADMS data shows that digitally excluded people are more likely to have concerns about privacy and scams than highly included people. For example, 30.3 per cent of highly excluded people have reduced their internet use because they were concerned about privacy and scams, compared with 7.9percent of highly included people. Concerns over privacy and fraud reinforce internet avoidance, creating an additional barrier to accessing and using technologies like internet banking.[63]

2.59Mr Claudio Mazzarella, General Manager, Everyday Banking, MyState Bank, told the committee that the 'sophistication of scammers and fraudsters is evolving' alongside advances in technology, and that awareness of potential fraud at the individual level is critical:

Fraud can be stopped at the individualsthemselves. What I mean by that is that the potential victim can be helped to become more literate when it comesto understanding the signs of fraud and the signs of what looks like a scam, which is absolutely important. Again,going back to how we've evolved the role of our branches and that in-branch coaching and support, we've alsohad some specifically themed sessions where customers can come in and learn about something. One of the morerecent ones that we've had has actually been around scam awareness and helping build the customer's awarenessof it and what to look for, because we think it's important. Regardless of age and regardless of your preferences,everybody is impacted by fraud in various channels.[64]

2.60In responding to increased threats of fraud through online channels, MrMattComyn, Chief Executive Officer, CBA, advised the committee that CBA invests about $750 million per annum to protect against cyberfraud, scams and financial crime.[65] This level of investment is achievable for the major banks but is harder for mid-tier lenders. Mr Clive van Horen, Chief Executive Officer, Suncorp Bank, explained that 'access to funding, cost of funding, cost of capital and the ability to deal with regulatory challenges' all affect the ability of the bank to confront challenges, including fraud and scams, at a larger scale.[66]

Older Australians

Box 2.4 Case study—Difficulties with digital banking

I've been with the Commonwealth Bank in Junee for 80 years. I have here my passbook from 1943, when I was nine years old, for the Junee bank, and I'm still with them. I need cash because all this technology came in after I grew up. I couldn't use that ATM out the front to save my life. I was too busy raising a family of five kids.—Mrs Maisie Robinson.[67]

2.61Older Australians are particularly susceptible to digital exclusion. The committee heard that the elderly are more likely to trust in processes they are familiar with and may not have the information technology skills required to switch to digital banking.

2.62The ADMS reports that the digital divide between younger and older Australians is most severe when it comes to the tasks people can undertake online, and their confidence in conducting them. Many older Australians have only basic operational skills, such as downloading and opening files or connecting to the internet. Some lack even these most basic skills. The divide is particularly acute in regional areas.[68]

Figure 2.22022 Index scores by age group, capital cities vs. Australia

Source: ARC Centre of Excellence for Automated Decision-Making and Society, Submission 582, p. 7.

2.63Councillor Ramon Jayo, Mayor, Hinchinbrook Shire Council, told the committee that the majority of the elderly population in his shire have limited education and find it difficult to learn new systems and processes. Most do not own a smartphone or have an internet connection, leaving them reliant on friends and family to do their banking for them.[69] This concern was been echoed elsewhere, with Isaac Regional Council also reporting that elderly customers are more limited in their ability to travel long distances to the nearest branch. Limitations on travel has made them more likely to withdraw larger amounts of cash, resulting in heightened security risks.[70]

2.64Isaac Regional Council also raised the issue of the many older Australians still operating on a passbook system. The passbook system requires records of deposits and withdrawals documented in the customers passbook and imprinted with the official bank stamp.[71] It has been estimated that, as of early 2020, over 100 000 people continued to use passbooks.[72]

2.65Mr Peter Lock, Chief Executive Officer, Heritage and People's Choice, told the committee that his smaller bank has deliberately continued passbook services due to their usage by elderly members of the community.[73] NAB has also allowed the use of passbook services through Bank@Post at Australia Post outlets,[74] although it was noted by other witnesses that using passbooks at the post office still requires the use of a transaction card.[75]

2.66Some banks have made efforts to create services to cater specifically to the elderly. Mr Scott Spittles, General Manager, Personal Banking, Bankwest, told the committee that Bankwest has been investigating the opportunity to provide 'priority telephone services' to elderly and vulnerable customers who need extra care and support.[76] This service would essentially allow vulnerable customers to 'jump the queue' and ensure they get priority assistance.

English as a second language

2.67Many issues in digital connectivity faced by the elderly are shared by those for whom English is a second language. Moira Shire Council described the difficulties faced by Pacific Australia Labour Mobility workers in their region as a result of bank branch closures. Many of the workers employed under the program have limited English and little understanding of the requirements to open a bank account. For affected workers, opening or making changes to an account requires taking half a day or more off work, often without pay, to get to another branch. Many of these workers do not drive and must find their way using the one bus each day that travels to and from Shepparton. Even so, while this allows them to talk to someone face-to-face, it is usually without the support of their Community Liaison staff member.[77]

2.68Moira Shire Council advised that the only other option is for a Community Liaison staff member to call the bank and try to convince the bank personnel that the staff member can act, and ask questions, on the worker's behalf. This process has proven to be difficult and frustrating for all involved. Alocal bank branch enables face-to-face discussions both with and without Community Liaison assistance, which can reduce these frustrations.[78]

2.69Banks claim that customer preferences are driving the transition to digital banking. However, many people have never been given a choice and are instead being pushed to move online. Often, these are the same people for whom transitioning to digital banking is most difficult.

2.70Communities in remote Australia face unique issues and conditions which can exacerbate problems caused by a lack of access to banking services. Extreme isolation, socio-economic issues, and declining services have all contributed to making access to financial services a more acute issue in remote areas than in other parts of the country.

2.71In travelling to places like Tom Price and Cloncurry, committee members were moved by challenges faced in these communities, and the lack of support provided by the banking industry. Remote communities continue to require access to cash and services at higher levels than other parts of the country.

2.72This chapter presents evidence on:

unique issues faced by people in remote communities in accessing banking services;

particular problems faced by Indigenous Australians;

potential solutions, including service hubs, mobile banking and community banks; and

the future of the cash-in-transit industry.

2.73The chapter ends with the committee's views and recommendations.

Service access issues in remote communities

2.74This section will examine issues faced by remote communities in accessing banking services. The committee heard that these include:

distance to services;

inaccessibility due to extreme weather events;

inability to keep up with the pace of closures and digital advances impacted by branch closures; and

language barriers.

The tyranny of distance

2.75The main issue faced by remote communities is the substantial distance needed to travel to access basic services, including banking. The closure of bank branches exacerbates existing pressures relating to the isolation of these remote towns and makes it more difficult for communities to access needed services.

2.76Ms Carlen Woods, Regional Manager, Ashburton Aboriginal Corporation, told the committee that Indigenous communities in Wakathuni, Bellary, and Youngaleena already had to travel large distances to access banking services prior to their closest bank closing in Tom Price. Now, they have to travel over 500 kilometres to their nearest branch. This trip is made even harder due to the lack of public and private transport options and licensing in these communities.[79]

2.77ICAN provided an example from a community member who detailed how difficult it can be to undertake basic banking matters when distance is a factor:

For communities in the [Northern Peninsula Area], it is necessary to travel significant distances over water or unsealed roads to either Thursday Island for a NAB branch, or Weipa for Qld Country Bank. Such travel is prohibitively costly and time consuming, particularly for people on low incomes. Transportation is not always accessible to these places either.

When we sought documents from the bank in relation to their customer, we received the following response:

We are still unable to process your request regarding personal data in regards to our mutual client, XXX. Unfortunately we do not hold any form of Identification on their profile. Can you please refer the client to their nearest CommBank branch at their earliest convenience and we will resume processing once Identification has been updated.

The nearest CBA branch for our client to attend and identify himself was Cairns – a 12-hour drive over a distance of more than 900 kms.[80]

Accessibility due to extreme weather events

2.78The tyranny of distance is further exacerbated by the wet season and extreme weather events. In some instances, communities are cut off almost entirely during the wet season. Trips can often be costly and onerous.MrsSylviaWinkler, Chief Executive Officer (CEO) of the Nintirri Centre, told the committee that, during the wet season, residents are forced to take longer routes to the nearest bank, resulting in one-way trips of up to six hours.[81]

2.79Mr Tony Hampton, CEO, Traditional Credit Union (TCU), told the committee about the difficulty in accessing remote communities during the wet season and how TCU, as a small banking provider, tries to overcome it:

These communities are hundreds of kilometres apart—and they're affected by weather. So, even to get to them, when it's the wet season, you've got to take a small plane. When the small planes aren't flying, you can't get to them, so we have to use technology to get to the staff that are there. That's why we have gone with satellite technology; it's so we can continue those services. But, overall, it's almost impossible to run a branch in a small remote community.[82]

2.80In its submission, TCU elaborated, further saying that when weather events have not only cut off roads but also affected digital connectivity, services 'cannot bedelivered by phone or digital channels' and are 'just not available for significant periods of time'.[83]

Pace of closures and the digital divide

2.81The lack of digital connectivity in remote communities was raised by a number of witnesses who expressed concern about inadequate internet infrastructure, connectivity issues, and high cost of devices. Ms Jillian Williams, Operations Manager, ICAN, said that connection generally requires a 4G network, 'but in reality people can really only connect through 3G networks, which we understand Telstra is removing'.[84]

2.82Professor Julian Thomas, Centre of Excellence for Automated Decision-Making and Society, told the committee that the fast pace of digital innovation makes it difficult for communities without the necessary infrastructure to keep up and further increases the digital divide between remote communities and those in metro areas:

The problem is that we're dealing with a bit of a moving target. You can see this with the banking issues in particular. As our society and economy transitions more to digital services, those who are somewhat behind can fall further behind very quickly. That's really the difficulty, that what would have been an adequate internet service 10 or 15 years ago is no longer really sufficient for the provision of the sorts of digital services which governments and organisations like banks are now providing. It's that moving target problem which is the issue here.[85]

2.83ASIC further outlined how digital-first banking requires access to devices and capacity to use digital platforms. This is not always available in remote communities where First Nations people 'may not only have limited access to reliable internet and phone reception, but also devices, as well as limited capacity to use available digital platforms and services'.[86] TCU elaborated further on this in its submission, stating that 'the use of mobile phones banking has been less extensive due to affordability, the assumption by digital application providers of one phone/one person and the complexity of accessing information and functionality'.[87]

2.84On the increasing pace of moves towards digital banking, Ms Anna Bligh, CEO of ABA, defended the transition, saying that although some customers find it difficult to keep up with changes it is important for banks to follow the trends and continue expanding their digital options.[88]

2.85Although the banks may be responding to trends in consumer access, further consideration needs to be given to those in areas where these trends do not hold. Ms Williams explained that even when customers are open to transitioning to online platforms, the move may be impossible:

[T]he removal of branches has occurred well ahead of advancements in digital connectivity and digital inclusion across regional and remote Australia. This means that, even if people wanted to move to online banking, the lack of mobile connectivity and a reliable internet connection means that they simply can't.[89]

2.86Difficulties resulting from the pace of digital innovation have been compounded by the increasing rate of bank closures in recent years. Independent journalist, MsDale Webster, explained that even during the course of the committee's inquiry, banks have continued to desert regional Australia:

Fifteen towns have been left completely without banking services: Holbrook, Coober Pedy, Tailem Bend, Carnamah, Smithton, Clifton, Alexandra, Roxby Downs, Jeparit, Biggenden, Tatura, Woolgoolga, Inglewood QLD, Mitchell and Waroona.[90]

2.87To combat the issue of poor digital connectivity, low orbiting satellites, including those provided by Starlink, have been raised as a potential solution to the connectivity problems faced by remote communities. Such satellites work by orbiting closer to Earth than typical geostationary satellites, thereby reducing latency and providing a reliable option for remote areas.[91]

2.88Professor Thomastold the committee that the low-orbiting satellites 'open up a range of really potentially significant possibilities' including the ability to make calls and texts directly from a mobile through a satellite system.[92] As an example, Mr Hampton explained that the TCU has already begun using the technology to bring connectivity to remote areas:

[A]ccess is very difficult from a bandwidth perspective, even where there's 4G in place. It does go down to 3G, and then the capacity of the towers is taken out. As there's more streaming that goes through applications and those sorts of things, it means that there's more demand on it. We, having branches in the community, have used the Starlink satellite over the Sky Muster because the Starlink is just far better. Its low orbit means it cuts through all the cloud, so it's not affected by the weather. What we're doing now is rolling out hotspots using that satellite capacity, so that people can get access to the internet via a satellite.[93]

2.89Despite these benefits, there are also drawbacks to the service provided by satellite companies. Starlink, for example, is cost prohibitive for some users, with plans costing up to $179 per month.[94] The high cost in comparison to other services may prove too much for vulnerable people in remote communities. MrDrew Norrish, CEO, Mackerel Islands Pty Ltd, also questioned what would happen if communities were reliant on a service provided by a foreign company:

[H]ow much trust do we have in an American company? What is our default if that fails? What are we left with? We're very resourceful up in these parts; we always have a plan A and a plan B. With plan A being Starlink, I'd say we don't really have a plan B if things go bad.[95]

2.90The cost of service provision is not only an issue for customers in remote communities. For providers, servicing isolated customers can be costly and is often done as a form of social obligation. The TCU is an authorised deposit-taking institution (ADI) owned by its Indigenous customers, with a goal of delivering services to remote Indigenous communities. However, Mr Hampton outlined how difficult a role that can be:

The banks are commercial organisations, so they're looking to make a profit. In remote Indigenous communities, there is profit to be made with the larger Indigenous corporations, but there is no profit to be made in looking after mums and dads and families in the community, where they're largely welfare dependent. You're providing a banking service so that they can live appropriately and can get on with their normal lives.[96]

2.91According to Mr Hampton, decision-making by the banks, which isbased on profit motives, 'starts to unravel the fabric of the community' and results in loss of employment and training opportunities. For the TCU to survive, it has endeavoured to keep running costs down by providing branches that are 'a hole in the wall, where you walk up to them from the shopping mall or the street and order your coffee'.[97]

Language barriers

2.92Language difficulties have also been an issue for Indigenous Australians. Digital applications and systems are frequently provided in English, with limited other languages available, and rarely, if ever, Indigenous languages. In the rare circumstance where someone has access to a digital device, they can be hampered by the lack of non-English options.[98]The use of Aboriginal-English by FirstNations consumers is also often not understood by service providers.[99]

Box 2.5 Case study—Barriers faced in First Nations communities

A community organisation was approached by several First Nationscommunity members who could not access their bank accounts as theyhad been locked out by the bank. The customers could not purchaseessentials like food for their families. The community organisation assistedthe community members to engage with the bank by phone. The bankadvised that the accounts had been locked because the customers neededto re-identify themselves.

The community organisation was required to use its limited resources tophone the bank, print identification verification documents, assist thecustomers with completing the documents, fax the paperwork to the bankand contact the bank again. They were required to wait on the phone againto confirm the identification and wait for the bank accounts to be unlocked.This took significant time and resources from a not-for-profit communityorganisation, which is not funded to provide this type of assistance. Theorganisation stepped in due to the serious welfare implications ofcustomers being locked out of their accounts.—anonymous case study provided by ASIC.[100]

2.93ICAN acknowledged that the major banks have implemented dedicated phone lines for Indigenous communities. This initiative recognises that there is a need to overcome barriers to banking and to provide easy access to services with appropriate support. However, these services have sometimes fallen short of this objective:

First Nations customers have experienced long wait times, inconsistent information, language barriers and limitations on what services can be provided through these lines before a referral has to be made to another department. People are having to constantly identify themselves and restate their story in order to get the service they require, knowing that they can't go into a local branch and get the matter sorted if there is no local branch to provide the service. If these dedicated services are not adequately resourced and valued by the corporate entities providing them they have the effect of further disadvantaging the very people they seek to support.[101]

Barriers to banking services in remote Indigenous communities

2.94In February 2023, ASIC released the Indigenous Financial Services Framework (the framework).[102] The framework outlines important insights on 'First Nations peoples' access to and engagement with the financial system' developed by ASIC during a consultation process with First Nations consumers and communities.[103] Four key learnings were developed for the framework:

(1)First Nations peoples had unique, established economies before colonisation. These economies continue today, and should be understood, respected and maintained.

(2)First Nations peoples have been prohibited and excluded from participating in the Australian financial system.

(3)Financial wellbeing affects all aspects of First Nations peoples' lives.

(4)First Nations peoples have many different versions of financial success. This needs to be accepted and encouraged. All First Nations peoples should be empowered to achieve their vision of success.[104]

2.95ASIC submitted that 'housing stress, the impact on physical and emotional health, poor access to education opportunities and limited service provision' all contribute negatively to First Nations peoples' financial wellbeing, as identified under key learning three.[105] These impacts are directly related to historic exclusion from the financial system:

These lasting impacts are particularly significant for First Nations peoples when considering the Framework's second key learning—that historic legislation, policies and events have prohibited and excluded First Nations peoples from effectively participating in the financial system. Engagement with and access to financial services in remote areas has been particularly inconsistent, and less embedded in day-to-day life than in metropolitan areas. This particularly applies to banking.[106]

2.96ASIC further noted that the impacts of bank branch closures are more pronounced when 'banks apply standard policies and procedures to all consumers, including First Nations consumers, regardless of whether they can easily attend a bank branch or access other banking channels'.[107] Further barriers to access include language barriers due to a shortage of Aboriginal-English interpreters, and personal identification requirements where lack of documentation may be an issue as a result of historic policies and practices.[108]

2.97This was further supported by Ms Woods, who described the difficulties her organisation has faced in aiding Indigenous jobseekers:

A lot of people don't actually have access to online banking. They didn't have enough ID to start with. We had an incident with a jobseeker from Bellary. We gave her a phone so that she could be contacted. We then tried to activate the phone so that she could have the phone available. We tried, but then she didn't have enough ID, and she had to then go all the way to Hedland. She couldn't prove who she was over the phone with the ID that she had, so she had to go over to Hedland to do that.[109]

2.98CatholicCare NT (CCNT) provided an example of the lack of support from Westpac after the final bank branch in Tennant Creek was closed. Westpac advised that customers could get support over the phone through a dedicated Indigenous Connect Team following the closure. CCNT told the committee that wait times for the service were up to two hours and it was not adequately resourced. Further, the support line 'does not use interpreters or employ enough First Nations staff to provide an appropriate level of care to their customers'. There is often gap between the expectations of Westpac agents and the financial knowledge and resources of customers in remote communitites, including access to identification documents.[110]

2.99The TCU acknowledged that First Nations customers are often less profitable for a bank:

The current model has a significant reliance on lending and other commission or fee-based products to significantly subsidise transaction and saving products. The current model assumes that if a branch of a bank is not reflecting a positive revenue contribution the branch is considered unviable. Unfortunately, the branch may have significant volume of transaction accounts that are high in transactions and low in balances, reflecting a real need for the physical channel by its customers, but they are the wrong customers for that branch to be considered sustainable.[111]

2.100In remote communities, 'the majority of housing is social housing, the majority of personal loans are for small amounts (micro-finance), and the majority of business is high volume transactional accounts with small balances', making branches in these areas unviable according to the current model.[112]

2.101Using cash as the primary method of transacting is preferred in remote indigenous communities due to its portability, lack of need for technology, and simplicity. The TCU told the committee that advances in digital technology have had a negative effect on Indigenous inclusion, as 'confusion and complexity for Indigenous people living in remote communities' has deterred people from taking up digital options and encouraged a return to cash as the primary method of transacting.[113]

2.102It is important that any proposed solutions to the impacts of bank branch closures consider the unique circumstances of remote and Indigenous communities. Indigenous Business Australia (IBA) made it clear that proposed solutions should 'consider the appropriateness of standards and rules to ensure a minimum threshold level of banking services are provided' in remote communities.[114] IBA also suggested that banks with Reconciliation Action Plans and Financial Inclusion Action Plans should review them and find ways to provide services to customers who may not have the skills or technological devices required to access online banking services.[115]

Limitations of Bank@Post

2.103In closing branches, banks have proposed the Bank@Post service through Australia Post as a possible solution and replacement for services in areas left branch-less. CBA told the committee that ensuring customers have access to services through online means or via Bank@Post is taken into account when considering closures.[116] NAB advised the committee that over 93 per cent of transactions that are undertaken in NAB branches can be done through Bank@Post.[117]

2.104Bank@Post is a banking service provided through the Australia Post network on behalf of 81 banks and ADIs. The service allows customers to deposit and withdraw cash at over 3500 Post Offices across Australia. Of these, 1800 are located in rural and remote areas. Australia Post estimates that there are approximately 1150 regional communities that have a Post Office but no bank branch.[118]

2.105In 2018, new agreements were struck between the banks and Australia Post to address a shortfall of funding for local post offices. Prior to the agreement, the provision of services resulted in a net financial loss for licensees due to costs being greater than what the agreement brought in. The new deal has resulted in the banks providing increased financial support for community access to banking services after closing their own branches. ANZ is the only one of the major banks to not hold a Bank@Post agreement. LPO Group reported that the reformed agreement resulted in 'many communities seeing increased economic results flowing through local businesses and households' and that 'cash remained circulating in the communities because it was retained and continued to be available locally'.[119]

2.106Agreements between Australia Post and the banks differ with each institution. The agreements set out fee terms and services to be offered on behalf of each individual institution. This means that customers have different services and limits available to them based on which bank they are with. These limits vary considerably and generate significant inconsistencies for customers. It also makes it difficult for Australia Post employees to effectively aid customers if they are having to navigate differing service terms.[120]

2.107Services differ across each institution but typically include cash withdrawals, deposits, and in some cases, account balance checks. For example, NAB advised the committee that their agreement provides for up to $2000 per day in cash withdrawals and up to $9999 in cash deposits per day with a linked debit card. They do not provide for balance inquiries.[121] In contrast, Bankwest also has an agreement for up to $2000 per day in cash withdrawals but offers only $6000 in cash deposits.[122] Standardisation of Bank@Post agreements was suggested by the Regional Banking Taskforce which recommended that 'Australia Post and banks should work together to standardise a basic level of service for Bank@Post, where customers are able to withdraw and deposit standard maximum and minimum amounts that could be easily communicated to customers'.[123]

2.108The committee heard evidence from witnesses that the Bank@Post service is limited as a replacement for bank branches due to the lack of banking services available. Certain vital services, including resetting PINs, setting up cards, and checking potential suspect transactions, are not available through Australia Post. Customers must instead travel to the nearest bank branch in another town.[124] The inability to offer a full suite of services renders Bank@Post a poor substitute for a full branch. Services offered are at the mercy of participating banks and what they are willing to pay for, as evidenced by ANZ's refusal to participate in the service.[125]

2.109Mr Etherington detailed the limitations of post offices as a banking service supplier:

For instance, we only provide a fraction of the services you can access from an ATM machine. The sorts of things that you can do at an ATM—you can't do many of them in our outlet. In our post offices you don't have access to the cash limits that you have access to at an ATM. If you want to make a deposit into a BSB or account number, which you can do at a bank branch, you can't do that with us. There are lots of transactions you can't do.[126]

2.110LPO Group submitted that cash services are limited by security levels at local post offices, available cash collection services, and withdrawal limits agreed between the banks and Australia Post. For community groups and small businesses who need cash floats to operate, it is often impossible to get required denominations and amounts for daily operations. Large cash deposits from local school canteens are a typical example of restrictions limiting the ability of small operators to transact.[127]

2.111LPO Group highlighted the pressures placed on communities by these limitations by relating the story of a licensee who was required to travel and withdraw their own money to float the Post Office:

[We withdrew] our own, personal money ($5000 to $10 000) and then deposit it to our account at our [Post Office] so we had money to keep our doors open until Armaguard turned up (once a fortnight). All I got from [Australia Post] was that we shouldn't do that, but we had no choice. [Australia Post] was very disappointing through this process, as always.[128]

2.112Further concerns were raised about the security of the Bank@Post service. Ms Myrna Ellery, Member, FSU, raised the issue of training for post office staff compared to bank tellers in recognising abuse and fraud:

[P]ost office staff are not trained bankers. Unlike professional bank staff, like myself, they've not had the training to identify things like money laundering, financial elder abuse, phishing and fraudulent transactions. This creates a massive loophole that circumvents all the work that has been done to protect bank customers in recent years.[129]

2.113Ms Natalie Heazlewood, Director, Skills, Employment and Small Business, Australian Chamber of Commerce and Industry, raised privacy issues that can eventuate as a result of banking through the local post office, noting that Bank@Post 'should not be seen as a replacement for an actual bank' and that members are 'concerned about the amount of information—private information—that someone who potentially runs the service would be able to have access to'.[130] While the Bank@Post service has been largely useful for basic, small transactions it is not an adequate substitute for full bank branches.

Impacts of branch closures on individuals

2.114The committee heard numerous personal stories from submitters and witnesses detailing the negative impacts of branch closures. Submitters have described their frustration at increased travel times and fear for their own personal security as a result of the lack of banking options.

2.115Of particular concern for those in regional areas was the time and distance required to travel to access a bank branch in the wake of closures in their own town. Increased fuel costs, loss of wages, and a reliance on family and friends are now factors when undertaking routine banking tasks. This is particularly acute in areas with limited transport options. The Shire of Carnamah gave an example of a typical banking trip for one of its residents:

Simply put, the majority of Westpac's customers residing in Carnamah and surrounds have a 240 [kilometre] round trip to access an essential financial service, such as personalised financial advice, replacement cards, detailed personal banking advice or ID recognition. Those that do not have access to a (dependable) vehicle will need to take a bus on either a Tuesday or Thursday to Moora from Carnamah. Moora is the closest bank branch and some 120 km from Carnamah. The trip is under 2 hours but for the return to Carnamah, you will need a 2 night stay in Moora. Accordingly, when you need face-to-face banking and without access to a vehicle, Westpac's decision to close our Carnamah branch will be devastating.[131]

2.116The cost of fuel for a round-trip of a similar distance in the example given here was estimated at $60 to $106 for those that have a private vehicle, excluding vehicle wear and tear. Where regional transport options are available, return costs can total between $56 and $116.[132] As the cost of living continues to increase, these added fuel costs can add pressure to a struggling household budget.

2.117The distances and costs of travel can be especially frustrating when it takes multiple trips to deal with an issue or when key staff are not available. MrGeoffrey Sheridan, Principal Administrator, District Council of Coober Pedy, detailed the experience of the District Chief Executive Officer travelling to his nearest Westpac branch, located 540 kilometres away in Port Augusta, only to be turned away:

One of the major issues we have is that whenever we need to change signatories on bank cards or anything else, or whenever any of the staff need to change signatories, we have to turn up, face to face, in Port Augusta, 540 kilometres away … We've had a relieving CEO in and he was on his way to Adelaide and thought, 'Well, we'll just do the bank card change. I'll just call into the Westpac bank in Port Augusta.' He thought they would be able to just sign his identity and do the transfer. He got there and they said, 'Oh, no. You need to be face to face with one of the managers,' and he said, 'Alright. Can I see the manager?' 'Oh, no. He's busy,' and he said, 'Well, when will he be available? Can I make an appointment?' They said, 'Oh, no. Sorry. He's busy all afternoon. You'll have to come back tomorrow.' That's the sort of treatment that we get.[133]

2.118When asked if this was acceptable, Mr Ross Miller, Chief Customer Engagement Officer, Westpac Group, responded saying that it was not and that the bank would 'encourage customers, if they need something, to make a booking with [the bank] prior to arrival so we can be sure we have the right services for them'.[134]

Security risks

2.119Witnesses also warned the committee of the increased security risks placed on individuals who take fewer bank trips now, due to the long distances needed to travel. As the accessibility of deposit-taking points declines, people are facing risks associated with keeping cash on hand for longer and banking in larger amounts. This presents an increased security risk and attracts potential thieves.

2.120It is not only the threat of robbery that increases with bank closures. As banks transition to online platforms, the risk of financial abuse of vulnerable people also increases. Lack of face-to-face banking facilities can expose older people, disabled people, and victims of domestic abuse to a greater risk of financial abuse.

2.121The Economic Abuse Reference Group (EARG) cited Deloitte Access Economics statistics showing that 43 Australian women were subjected to financial abuse every hour in 2020.[135] Financial abuse can take many different forms including:

accrual of debt in the other person's name;

not contributing to joint loans;

controlling of finances;

withholding necessities; or

preventing access to employment and education that would provide the means of financial independence.[136]

2.122EARG advised the committee that, although electronic banking is convenient, it can aid in facilitating financial abuse. Perpetrators can coerce victims into signing loan documents electronically, sharing PINs, or gaining access to banking accounts and authentication methods. Victims may also willingly give information to a potential perpetrator if they feel vulnerable due to factors including age or language barriers.[137]

2.123Mrs Quinta Lahtinen, Senior Leader, Client Services, Hinchinbrook Community Support Centre, told the committee about the support required by victims of financial abuse:

A significant proportion of our domestic and family violence victims do suffer financial abuse and, with the support of a community agency, may need to go into the branch to have face-to-face control for the first time in their relationship to open their own bank account or have access to their own funds because, as we are aware with domestic and family violence, financial abuse could mean that the aggrieved doesn't have any means of accessing their own income.[138]

2.124Having access to face-to-face banking at a branch reduces the risk of financial abuse. Bank staff can recognise the signs of financial abuse, check that the person transacting for someone else has appropriate authority, aid customers who lack confidence in electronic banking, and provide a means for a victim to raise their situation and request assistance.[139]

2.125Banks are becoming more aware of financial abuse and have taken measures to address the issue. The ABA recognised that family and domestic violence is a whole community issue and has released the Financial abuse and family and domestic violence guidelines to identify warning signs of financial abuse.[140] However, the FSU argued this is only effective if in-branch interaction is possible. Professional branch staff have had training to identify money laundering, financial abuse, phishing, and other fraudulent transactions.[141] The committee heard that this cannot be replaced by electronic banking.

Impacts of branch closures on communities and businesses

Threatening the socioeconomic viability of towns

2.126The impact felt when a bank closes the last remaining branch in town can go further than losing access to cash and services. The loss of a local bank branch can isolate communities and limit economic opportunities. Evidence provided to the committee suggested that flow on effects include loss of professionals and entrepreneurs, reduced foot traffic for small businesses, and increased risk of crime and robbery.

2.127Regional councils and local governments described the added difficulty in attracting and retaining residents as a result of branch closures.[142] The loss of in-branch banking can lead to a reduction of other retail offerings and services. When services leave a small community, it can be challenging to re-attract them. The prospect of attracting new investors diminishes if there are fewer banking services in town.[143]

2.128Ms Diane Barr, Vice Chair, Tasmanian Women in Agriculture, told the committee that the flow-on effects of bank closures have dire effects on regional areas:

[C]ash management facilities are an essential service, especially in regional and remote areas. Loss of banks adds to the loss of professionals in a small community, and this has knock-on effects. The schools close and then the GP leaves, and it really is the death knell to small regional and remote areas.[144]

2.129In areas with limited employment opportunities, banks can provide an important alternative industry. Bank branches can support the community in providing internship and work placement opportunities for young people in an office setting, thus providing an alternative career path to the agricultural and mining opportunities typically found in regional areas.[145] Having the option of developing a professional career path with a reliable employer can aid in convincing young people to stay in their home town. When a bank branch leaves, so do those people who may be suited to this style of work, which can now only be found in larger centres.[146] Dr Philip Keirle, Chief Executive Officer, Cloncurry Shire Council, estimated the lifetime value of losing six people from a town to be a loss of approximately $4 million, through loss of rates, leases and grocery spend, among others.[147]

2.130It is not only young people that migrate out of regional towns when a branch closes; so too can the business of those residents who remain. It is not uncommon for people in regional areas to run numerous errands on a trip into a local town. When a bank closes, forcing people to bank elsewhere, the foot traffic and transactions reduce for other local shops and businesses, instead being conducted in the major regional centre where the closest bank is located.[148] This practice, known as 'escape expenditure', is good for the larger town with the bank branch but not for the smaller town where the customer lives. Money for groceries, coffee, farm equipment, or other small purchases that would previously have been spent in the small town instead follow the bank branch out of town and to the larger centre where it is more convenient for people to shop while banking.[149]

Community groups and organisations

2.131Banks also provide support to communities in other ways. They often sponsor local events, sporting teams, and community groups as well as providing donations to local not-for-profits. When a local bank branch leaves town, the loss of support hinders the growth of these community organisations, further impacting the liveability of these regions and the ability to attract and retain residents.[150]

2.132The lack of in-person banking services also affects the administration of local groups and organisations. Community groups that are typically run by volunteers and require multiple people to have oversight of funds have reported difficulties in administering basic duties. Mrs Janessa Bidgood, President, Curry Merry Muster Festival, told the committee about the difficulty in organising for account signatories to be updated:

We require three signatures on our banking to get anything done. Our committee changes all the time; we have different secretaries and different treasurers and that sort of stuff. Every time that changes, someone needs to go to the bank and sign on new signatories. We can't get three people to Mount Isa together from our committee. We all work different jobs; we all work different hours. To get everyone up there together to do it is a problem. It really matters a lot to have that bank here, for that reason.[151]

2.133Other witnesses likened the process of updating details as being akin to a 'military operation' where they must 'provide all the documentation without error'.[152] Banks often require office holders to assemble at the branch at the same time. A Western Queensland Alliance of Councils survey, conducted across 22 councils, estimated the average round trip for communities without a bank branch to be anywhere from four to twelve hours.[153] Excess travel time makes it difficult to coordinate a group of volunteers who need to take leave from work or take time away from the farm for the purposes of a bank trip.[154] The onerous requirements and long-distances involved disincentivise people from volunteering for community roles.

2.134The committee also heard about indirect costs incurred due to the increased travel burden. Larger travel distances mean that small businesses need to employ extra personnel to transport cash. Some businesses instead choose to bank less often and, for those, the heightened security risk of keeping extra cash on-site has meant an increase to insurance premiums.[155] In some cases, local governments have stepped in to underwrite the cost of security services for businesses with large cash turnover.[156]

Box 2.6 Case study—Shorter hours, larger costs

Whilst working in the office of the largest grocery store in Bridgetown, I was responsible for banking cash and cheque takings each day, and keeping up adequate change for the tills. This often required visits to the bank more than once a day. Easy when the bank branch nearby was operating. For security, the cash float kept in the store was not huge. Since the removal of business banks in Bridgetown, larger stores have to pay for a secure courier to do their monetary transfers. This comes at a cost to the business, then to all customers with a flow-on cost from this expense having to be covered in the pricing structure … Smaller businesses may close down half a day a week to transport takings to a physical bank and obtain change. This increases their security risk, both in holding takings for a week and for a staff or family member to transport the cash by private car. This creates added costs for the business, and reduces their trading hours.Judith Maddams.[157]

2.135Kingston District Council told the committee that 'deposit taking services provide business owners with peace of mind' by securely storing cash rather than having to keep it onsite at the business in a safe. Losing deposit taking institutions and ATMs means that 'businesses are unnecessarily exposed to overnight cash and security risks, as they are unable to deposit their takings into a secure night depository facility.' The exposure to unnecessary security risks due to the need to deposit their takings at a major banking hub is 'untenable' for business owners.[158]

2.136Unfortunately, the committee has heard of robberies that have occurred due to the increased security risk of keeping cash onsite. Mrs Barb Smallwood related to the committee an unfortunate incident that happened to a family member:

From a security point of view, I have a family member who is a shop owner in a country town, and they have to travel over an hour to go to their bank just to maintain their float. As such, they felt that they would probably reduce the number of times they had to do that trip and keep a higher float on hand. In making that decision, they felt that they should probably review their security and see where they're at, so they had someone come in and carry out an assessment. A few weeks later, they were cleaned out. It is really sad that something like that would happen. It was very clear that the people knew exactly where everything was stored, the best way to access and where all the cameras that they already had were. I think that's a real kick in the guts for us small-town people who are trying to do the right thing and get by.[159]

2.137Community groups also face difficulties in accessing and banking cash used for events. Local football matches, agricultural shows, school fetes, and similar community activities require a cash float to operate. They must also bank takings at the end of such events. Both of these needs are increasingly difficult to meet if there is no easy access to a bank branch.[160]

2.138When a bank leaves town it is frequently left to the local Post Office to provide basic banking services. However, LPO Group advised the committee that agreements on limits for the amount of cash to be transacted causes issues in supporting local events:

[L]ocal community groups who holdevents need cash floats upwards of around $20k to $80k, but these amounts areunavailable through Australia Post. Similarly, businesses that need cash floats for their daily operations are impacted where these amounts exceed thenegotiated Bank@Post agency limits or where the Post Office cannot meet thespecific denomination requirements due to the limited availability of thedenominations. Large cash deposits from local school canteens are a typicalexample of restrictions limiting the ability to accept such deposits, creatingissues for the locals who run the canteen.[161]

2.139The committee heard that people are having to source and hold cash floats in other ways due to the lack of access to cash. The Hon Terry Waldron, Chairman of Regional Development Australia, Wheatbelt, told the committee that people have resorted to holding cash floats in their own homes. Mr Waldron also stated that local independent grocers have called for nearby residents to exchange any coins they have for bank notes in order to maintain a cash float needed to operate.[162]

Committee view

2.140Bank branch closures are devasting to many regional and remote communities.

2.141Along with an increased need for cash, regional and remote communities are more dependent on face-to-face services. Many have a higher proportion of elderly, Indigenous and/or disabled populations, and may be particularly exposed by bank branch closures. Vulnerable residents and small businesses may be left 'high and dry', or forced to drive hundreds of kilometres to the nearest bank to complete essential and basic financial tasks.

2.142As well as disadvantaging individuals living in regional and remote areas, bank branch closures—particularly the closure of a community's last bank—often have a devastating effect on the town's morale. The loss of a town's last bank causes downstream economic impacts: businesses failing, other services relocating and people moving to be nearer to essential amenities.

2.143The committee believes Australia's banks are failing to take these impacts seriously. In many cases, banks are simply walking away from communities where they have been a mainstay for decades.

2.144Over the chapters that follow in this report, the committee considers why and how banks are closing branches, the adequacy of alternative service options and supports provided, and options for reform.

2.145The majority of the committee's conclusions and recommendations are provided in Chapter 5.

Protecting access to cash and financial services

2.146While the use of cash is declining, the committee heard that 'cash is still king' in the bush. There are many communities where cash remains necessary and is preferred for a variety of reasons.

2.147Cash has significant benefits for regional and remote communities, which can be affected by digital connectivity issues, lack of digital literacy, and cultural, linguistic or physical barriers to online banking.

2.148Community groups, clubs, school fêtes, markets and recreational events often rely on cash, including coins, and cash is frequently needed during natural disasters, such as when telecommunications networks fail and towns are cut off by road closures or extreme weather.

2.149Using cash may also reduce the level of transaction fees that both consumers and businesses pay to the banks, keeping more money in the regions.

2.150Treasury and RBA officials told the committee that the government is committed to maintaining ongoing access to cash for Australian citizens when and where they need it.

2.151While the committee welcomes this position, we believe that the government should adopt a formal position to guarantee reasonable access to cash and financial services as a right for all Australians. Given the pace of technological change, such a formal position would help lessen the anxiety that cash and financial services may be inaccessible in the future.

2.152Clearly not all Australians will be able to access the same level of financial services but financial services in the modern world are as important as electricity and telecommunications. They therefore should be a priority for governments in a way similar to their approach to these essential services.

Recommendation 1

2.153The committee recommends that the Australian Government adopt a policy recognising access to financial services as an essential service. To this end, it should commit to guaranteeing reasonable access to cash and financial services for all Australians.

Footnotes

[1]Jack Mulqueeney and Tanya Livermore, Cash Use and Attitudes in Australia, Reserve Bank of Australia (RBA) Bulletin, June2023 (accessed 19 April 2024).

[2]Reserve Bank of Australia (RBA), Submission 312, p. 1.

[3]Mr Matt Comyn, Chief Executive Officer, Commonwealth Bank of Australia (CBA), Committee Hansard, 20 September 2023, p. 2.

[4]Mr Comyn, CBA, Committee Hansard, 20 September 2023, p. 2.

[5]RBA, Submission 312, p. 2.

[6]Mr Tim Baird, Assistant Secretary, Payments System and Financial Innovation Branch, Department of the Treasury, Committee Hansard, 1 December 2023, p. 48.

[7]Ms Merylin Coombs, Deputy Head, Note Issue Department, RBA, Committee Hansard, 1 December 2023, p. 50.

[8]RBA, Submission 312, pp. 3, 5.

[9]Indigenous Consumer Assistance Network and Weipa Community Care Association (ICAN), Submission 475, p. 6.

[10]ICAN, Submission 475, p. 6.

[11]Australian Securities and Investments Commission (ASIC), Submission 542, p. 5.

[12]Mrs Sandi Wallace, Owner, Wallace's News and Drapery, Committee Hansard, 15 August 2023, p.31.

[13]Tasmanian Women in Agriculture, Submission 528, p. 2.

[14]See, for example: Kaaren Mitchell, Submission 66, p. 1; Tara Hammet, Submission 214, p. 3; Philip Gray, Submission 343, p. 2; Janis Eagle, Submission 545, p. 1.

[15]Mrs Janessa Bidgood, President, Curry Merry Muster Festival, Committee Hansard, 17 May 2023, p.31.

[16]Regional Development Australia Wheatbelt, Submission 323, p. 2.

[17]Ms Coombs, RBA, Committee Hansard, 1 December 2023, p. 52.

[18]Business Chamber Queensland, Submission 423, p. 6.

[19]East Gippsland Shire Council, Submission 80, p. 2.

[20]Ms Susan Curley, Chairperson, Cloncurry Local Business Network, Committee Hansard, 17May2023, p. 27.

[21]Mr Don McDonald, Chairman of MDH Pty Ltd, Committee Hansard, 17 May 2023, p. 23.

[22]MrAnthony Basford, Chief Executive Officer of East Gippsland Shire Council, Committee Hansard, 2 March 2023, pp. 25–26.

[23]Mr Peter King, Chief Executive Officer, Westpac Group, Committee Hansard, 20 September 2023, p.18.

[24]Australian Banking Association (ABA), Submission 428, p. 3.

[25]Catherine Clemow, Submission 579, p. 2.

[26]Mid Murray Council, Submission 380, p. 2.

[27]Armaguard, Submission 477, p. 1.

[28]Mr Mick Cronin, CEO, Linfox Armaguard, Committee Hansard, 1 December 2023, p. 81.

[29]Mr Cronin, Linfox Armaguard, Committee Hansard, 1 December 2023, p. 86.

[30]Mr Baird, Treasury, Committee Hansard, 1 December 2023, p. 51.

[31]Mr Cronin, Linfox Armaguard, Committee Hansard, 1 December 2023, p. 82.

[32]Ms Suzie Copley, General Manager, Policy, Coordination and Remedies, Australian Competition and Consumer Commission (ACCC), Committee Hansard, 25 March 2024, p. 2.

[33]Armaguard, Submission 477, p. 1.

[34]Armaguard, Submission 477, p. 1.

[35]Armaguard, Submission 477, p. 2.

[36]Mr Cronin, Linfox Armaguard, Committee Hansard, 1 December 2023, p. 82.

[37]Ms Michelle McPhee, Assistant Governor, Business Services, Reserve Bank of Australia, Committee Hansard, 25 March 2024, p. 7.

[38]Ms McPhee, Reserve Bank of Australia, Committee Hansard, 25 March 2024, p. 7.

[39]ACCC, 'Industry allowed to collaborate to facilitate sustainable access to cash', Media Release, 6December 2023 (accessed 21 May 2024).

[40]ACCC, 'Industry allowed to collaborate to facilitate sustainable access to cash', Media Release, 6December 2023.

[42]ABA, Submission 428, p. 5.

[43]Mr King, Westpac, Committee Hansard, 20 September 2023, p.14.

[44]Mr Ross McEwen, Group Chief Executive Officer and Managing Director, National Australia Bank (NAB), Committee Hansard, 20 September 2023, p. 23.

[45]Mr King, Westpac, Committee Hansard, 20 September 2023, p. 20.

[46]Finance Sector Union (FSU), Submission 381, p. 7.

[47]ARC Centre of Excellence for Automated Decision-Making and Society (ADMS), Submission 582, p.9.

[48]ARC Centre of Excellence for ADMS, Submission 582, p. 10.

[49]ARC Centre of Excellence for ADMS, Submission 582, p. 10.

[50]ARC Centre of Excellence for ADMS, Submission 582, p. 4.

[51]Mrs Quinta Lahtinen, Senior Leader, Client Services, Hinchinbrook Community Support Centre, Committee Hansard, 18 May 2023, pp. 41–42.

[52]Queensland Farmers' Federation, Submission 361, p. 2.

[53]Mr Ross Girgenti, Treasurer, Hinchinbrook Community Support Centre, Committee Hansard, 18 May 2023, pp. 42–43.

[54]Ms Charlotte Wundersitz, Senior Policy Officer, Trade and Economics, National Farmers Federation, Committee Hansard, 1 December 2023, pp. 22–23.

[55]Mr Stephen Capello, Chief Executive Officer, Hume Bank, Committee Hansard, 21 September 2023, p. 34.

[56]See for example: Australian Lottery and Newsagents Association, Submission 599, pp. 5–6.

[57]Australian Citizens Party, Submission 539, p. 10.

[58]Name withheld, Submission 211, p. 1.

[59]Mr Kevin Bertwistle, General Manager, Bribie Island Bowls Club, Committee Hansard, 16 April 2024, p. 11; Mrs Suzie Stride, Post Office Licensee, Bongaree Licensed Post Office, Australia Post, Committee Hansard, 16 April 2024, p. 14.

[60]Regional Development Australia, Submission 502, p. 8.

[61]Isaac Regional Council, Submission 287, p. 7.

[62]Mr Scott Etherington, Chair, Licensed Post Office Group, Committee Hansard, 1 December 2023, p.5.

[63]ARC Centre of Excellence for ADMS, Submission 582, p. 11.

[64]Mr Claudio Mazzarella, General Manager, Everyday Banking, MyState Bank, Committee Hansard, 19 September 2023, p. 3.

[65]Mr Comyn, CBA, Committee Hansard, 20 September 2023, p. 6.

[66]Mr Clive van Horen, Chief Executive Officer, Suncorp Bank, Committee Hansard, 18 May 2023, p. 39.

[67]Mrs Maisie Robinson, Committee Hansard, 21 September 2023, p. 42.

[68]ARC Centre of Excellence for ADMS, Submission 582, p. 7.

[69]Councillor Ramon Jayo, Mayor, Hinchinbrook Shire Council, Committee Hansard, 18 May 2023, p. 9.

[70]Isaac Regional Council, Submission 287, p. 5.

[71]Isaac Regional Council, Submission 287, p. 5.

[72]Ms Wendy Streets, Local Executive Secretary, Queensland, FSU, Committee Hansard, 2 March 2023, p. 44.

[73]Mr Peter Lock, Chief Executive Officer, Heritage and People's Choice, Committee Hansard, 17May2023, p. 19.

[74]NAB, Submission 402, p. 8.

[75]Ms Streets, FSU, Committee Hansard, 2 March 2023, p. 42.

[76]Mr Scott Spittles, General Manager, Personal Banking, Bankwest, Committee Hansard, 16August2023, p. 2.

[77]Moira Shire Council, Submission 359, p. 2.

[78]Moira Shire Council, Submission 359, p. 3.

[79]Ms Carlen Woods, Regional Manager, Ashburton Aboriginal Corporation, Committee Hansard, 13March 2024, p. 24.

[80]ICAN, Submission 475, pp. 4–5.

[81]Australian Securities and Investments Commission (ASIC), Submission 542, p. 7; Mrs Silvia Winkler, Chief Executive Officer (CEO), Nintirri Centre, Committee Hansard, 13 March 2024, p. 16.

[82]Mr Tony Hampton, CEO, Traditional Credit Union (TCU), Committee Hansard, 1 December 2023, p.76.

[83]TCU, Submission 425, p. 3.

[84]Ms Jillian Williams, Operations Manager, ICAN, Committee Hansard, 1 December 2023, p. 71. Telstra is scheduled to cease 3G services in June 2024.

[85]Professor Julian Thomas, Centre of Excellence for Automated Decision-Making and Society, Committee Hansard, 21 February 2024, p. 13.

[86]ASIC, Submission 542, pp. 7–8.

[87]TCU, Submission 425, p. 4.

[88]Ms Anna Bligh, CEO, ABA, Committee Hansard, 20 September 2023, p. 40.

[89]Ms Williams, ICAN, Committee Hansard, 1 December 2023, p. 71.

[90]Dale Webster, Submission 196.1, p. 6.

[91]Starlink,Technology, undated (accessed 5 April 2024).

[92]Professor Thomas, Centre of Excellence for Automated Decision-Making and Society, Committee Hansard, 21 February 2024, p. 17.

[93]Mr Hampton, TCU, Committee Hansard, 1 December 2023, pp. 71–72.

[94]Financial Sector Union (FSU), Submission 381, p. 22.

[95]MrDrew Norrish, CEO, Mackerel Islands Pty Ltd, Committee Hansard, 13 March 2024, p. 34.

[96]Mr Hampton, TCU, Committee Hansard, 1 December 2023, p. 75.

[97]Mr Hampton, TCU, Committee Hansard, 1 December 2023, pp. 75–76.

[98]Traditional Credit Union, Submission 425, p. 15.

[99]ASIC, Submission 542, p. 8.

[100]ASIC, Submission 542, p. 8.

[101]ICAN, Submission 475, p. 9.

[102]ASIC, ASIC's Indigenous Financial Services Framework, 13 November 2023 (accessed 10 April 2024).

[103]ASIC, ASIC's Indigenous Financial Services Framework, p. 8.

[104]ASIC, ASIC's Indigenous Financial Services Framework, p. 14.

[105]ASIC, Submission 542, pp. 5–6.

[106]ASIC, Submission 542, p. 6.

[107]ASIC, Submission 542, p. 6.

[108]ASIC, Submission 542, p. 8.

[109]Ms Woods, Ashburton Aboriginal Corporation, Committee Hansard, 13 March 2024, p. 24.

[110]CatholicCare NT, Submission 266, p. 2.

[111]TCU, Submission 425, p. 2.

[112]TCU, Submission 425, p. 2.

[113]TCU, Submission 425, p. 4.

[114]Indigenous Business Australia (IBA), Submission 208, p. 3.

[115]IBA, Submission 208, p. 5.

[116]Commonwealth Bank of Australia, Submission 429, p. 1.

[117]NAB, Submission 402, p. 7.

[118]Australia Post, Submission 544, p. 1.

[119]LPO Group, Submission 340, pp. 1–2.

[120]Australia Post, Submission 544, p. 3.

[121]NAB, Submission 402, p. 7.

[122]Mr Scott Spittles, General Manager, Personal Banking, Bankwest, Committee Hansard, 16August2023, p. 5.

[123]Treasury, Regional Banking Taskforce - Final Report, 30 September 2022, p. 16.

[124]LPO Group, Submission 340, p. 2.

[125]Australian Citizens Party, Submission 539, p. 14.

[126]Mr Scott Etherington, Chair, LPO Group, Committee Hansard, 1 December 2023, p.4.

[127]LPO Group, Submission 340, p. 2.

[128]LPO Group, Submission 340, pp. 4–5.

[129]Ms Myrna Ellery, Member, FSU, Committee Hansard, 2 March 2023, p. 50.

[130]Ms Natalie Heazlewood, Director, Skills, Employment and Small Business, Australian Chamber of Commerce and Industry, Committee Hansard, 1 December 2023, p. 34.

[131]Shire of Carnamah, Submission 250, p. 5. Note: Westpac Carnamah has closed since this evidence was given.

[132]Isaac Regional Council, Submission 287, pp. 3–4.

[133]MrGeoffrey Sheridan, Principal Administrator, District Council of Coober Pedy, Committee Hansard, 21February2024, p. 31.

[134]Mr Ross Miller, Chief Customer Engagement Officer, Westpac, Committee Hansard, 21February2024, p. 44.

[135]Economic Abuse Reference Group (EARG), Submission 519, p. 2.

[136]EARG, Submission 519, p. 2.

[137]EARG, Submission 519, pp. 2–3.

[138]Mrs Quinta, Senior Leader, Client Services, Hinchinbrook Community Support Centre, Committee Hansard, 18 May 2023, p. 41.

[139]EARG, Submission 519, p. 2.

[140]Australian Banking Association, Financial abuse and family and domestic violence (FDV) guidelines, 1April 2021 (accessed 22 March 2024).

[141]FSU, Submission 381, p. 9.

[142]Cassowary Coast Regional Council, Submission 476, p. 8.

[143]Isaac Regional Council, Submission 287, p. 4.

[144]Ms Diane Barr, Vice Chair, Tasmanian Women in Agriculture, Committee Hansard, 19September2023, p. 23.

[145]Ms Diane Colebrook, Secretary, Beverley Branch, Country Women's Association, Committee Hansard, 16 August 2023, p. 27.

[146]Tara Hammet, Submission 214, p. 2.

[147]Dr Philip Keirle, Chief Executive Officer, Cloncurry Shire Council, Committee Hansard, 17 May 2023, p. 6.

[148]Isaac Regional Council, Submission 287, p. 4; Cassowary Coast Regional Council, Submission 476, p.7.

[149]Latrobe City Council, Submission 353, p. 4.

[150]Business Chamber Queensland, Submission 423, p. 6; Peter Sutton, Submission 63, p. 2.

[151]Mrs Janessa Bidgood, President, Curry Merry Muster Festival, Committee Hansard, 17 May 2023, p.31.

[152]Mrs Chris Lane, President, Shire of Three Springs, Committee Hansard, 15 August 2023, p. 14.

[153]Western Queensland Alliance of Councils, Submission 535, p. 3.

[154]Isaac Regional Council, Submission 287, p. 4; Mr Bruce William Hunt, Secretary, Beverley Agricultural Society, Committee Hansard, 16 August 2023.

[155]Mrs Sandi Wallace, Owner, Wallaces News and Drapery, Committee Hansard, 15 August 2023, p. 31.

[156]Local Government Association of Queensland, Submission 377, p. 9.

[157]Judith Maddams, Submission 183, p. 2.

[158]Kingston District Council, Submission 358, p. 5.

[159]Mrs Barb Smallwood, Private capacity, Committee Hansard, 15 August 2023, p. 42.

[160]LPO Group, Submission 340, p. 4.

[161]LPO Group, Submission 340, p. 4.

[162]The Hon Terry Waldron, Chairman of Regional Development Australia, Wheatbelt, Committee Hansard, 16 August 2023, pp. 30–31.