Final Draft recommendations on financial inclusion
Dlu South
Issues in Bank Operations &
Recommendations
ISSUES
Banking among persons with disabilities:
Disabled people are not seen as potential customers by banking sector. The staff and authorities at the banks are not aware of the rights and requirements of persons with disabilities. Officials at banks in rural areas are not aware of the provisions and guidelines in RBI circulars.
Opening of Savings Accounts
Most people with Cerebral Palsy are only given a joint account. (Eg:Rajiv Rajan, Coordinator, Disability Legislation Unit, Vidya Sagar & P.S.Dheepakh, Sub Editor, The Hindu, Chennai)
Similarly many persons with cerebral palsy, autism, mental retardation and multiple disabilities are given a savings account only on guardianship.
In rural areas, many persons with intellectual disabilities are denied opening savings accounts despite having a guardian. Similarly Persons with psycho social disabilities are always denied bank accounts with and without guardians. Minors with intellectual disabilities are denied opening of accounts as they could not have a guardian before 18 years. Rural banks deny savings account to many persons with physical/visual/hearing disabilities by delaying the process of initiating an account, which doesn’t carry evidence.
Postal savings accounts are completely denied to people with intellectual disabilities. Though people with physical disabilities are provided postal accounts, they are denied active roles in further operations of their account.
People with disabilities living in institutions are denied banking services.
No frills account is issued to persons with Mental retardation & Autism very rarely. All transactions are executed by guardian / joint a/c holder without the knowledge of the individual with mental retardation in many cases.
Nominations are not accepted in joint accounts of people with (intellectual) disabilities.
Deposit & Withdrawal of Money
Thumb impressions of people with intellectual disabilities are not accepted. ATM Card & Cheque Book facility is denied to most people with intellectual disabilities (CP, Autism, MR & Multiple Disabilities). Individuals with disabilities are asked to come to bank in person. Despite having a joint account, people are demanded to go to the same bank for transactions.
Witness signature are demanded with thumb impression on chalan at bank while deposit / withdrawal for persons with deaf blindness.
In case of ATM facility provided for an account of a person with intellectual disability, it is provided in the guardian’s name and not in the disabled person’s name. Similarly in case of cheque book provided to the account of a person with intellectual disability, it will have to be issued / counter signed by the guardian.
The signature of a person with disability varying at different instances due to Motor Nerve Coordination in case of people with cerebral palsy and having the disability itself in case of people with Mental Retardation are reasoned out for not providing cheque signing authority and issue of cheque books.
ATM
Physical access is denied in most ATMs. The height and timing of operation at ATM is inaccessible.
Many people with Cerebral Palsy have difficulty in counting the money taken from ATM. Yet it should be noted that they would not require a guardian for counting but an assistant.
Current Account
Persons with intellectual disabilities are denied current account. Thumb impression is not accepted in current account. Current account was forcibly closed by the bank to a company owned by persons with intellectual disability as the thumb impression was claimed to be invalid. Example: Enlightened Enterprises, Chennai.
Loans
Persons with disabilities, especially those with intellectual disabilities are not provided individual education loans. They have to provide the surety of 2 people to avail the minimum educational loan which is not in the case of students without disabilities’.
Persons with disabilities face huge problems / are denied loans even under NHFDC for their self employment ventures. Loans are not provided individually without power of attorney or cheque signing authority to caretaker even to companies of PWD group.
Banks in rural areas claim that the loan provided to a person with disabilities cannot be recovered and hence deny loans. For a few people with intellectual disabilities who have succeeded in opening their accounts through guardians, rural banks claim that their guardians do not have any right to pledge property or take loans in their wards’ names.
In rural areas, a subsidy to a government scheme is provided by just giving the subsidy amount and getting signature from the person with disability as the loan has been provided to him / her and is repaid.
Self Help Groups of Persons with Disabilities
All members with different disabilities in a SHG are made to go to bank in person more than once while initiating group account and extension of credit.
If minors with disabilities or adults with Mental Retardation / Visual Impairment are involved in SHGs, some banks do not initiate account or extend credit to such groups.
The SHG members with disabilities have to stand and wait in queue for hours along with people without disabilities
Operation system
Persons with disabilities lack operation system support in banks for immediate attention and easy operation of their accounts / transactions.
Persons with disabilities are made to stand in queues / wait for a long time during initiating bank account or any further transaction.
Persons with disabilities are not kept informed about the transactions involved with their account in case of a joint / guardianship associated account.
Credit card machines and online banking are not provided to entrepreneurs with disabilities.
Investments of parents of adults with intellectual disabilities and their benefits are not provided to their wards without guardianship. The current guardianship mechanism is not strong enough to ensure that the benefits reach the wards.
Different norms prevailing in different banks to access loans & special allowances under different schemes makes it difficult for people with disabilities to access those benefits.
Rural banks are authoritative and autonomous and are not bound by the local panchayat or the district collector. No grievance redressal system and personal assistance for persons with disabilities in rural banks.
In rural banks, many bank staff as well as local people known to the account holders with disabilities manipulate signatures / thumb impressions of the account holders and withdraw money but goes without complaint.
Insurance Policies:
Persons with disabilities including those with intellectual / neurological / psycho social disabilities / disabling medical conditions are denied all insurance policies (life, travel, medical, property, etc).
Persons with disabilities who somehow succeed in getting an insurance policy are charged additional premium, given only base cover policy and not provided death benefit, medical policy or upgraded cover / policies.
RECOMMENDATIONS
POLICY
1. Banks must recognize that persons with disabilities have the right to respect to inherent dignity and any such act of the banker / banking system / documents including products and services inter alia use of language, gesture, etc that is in derogation to persons with disabilities amounts to inequality, discrimination and degradation of the account holder with disability.
2. Banks must recognize that every person with disability has inherent capacity to access all products and services delivered by banks.
3. All Banks as also IBA shall add the term ‘disability’ in their standard non-discrimination clause where it is mentioned that services will be offered to all without any discrimination based on caste/religion/gender etc.
4. Measures shall be taken to promote banking among disabled people in rural and urban areas, so that more disabled people open accounts and avail banking services as well as make banks aware of their responsibility to clients with disabilities.
5. A core committee on Banking services for persons with disabilities with adequate representation of persons with disabilities should be formed. The committee shall conduct periodic consultation with persons with disabilities across the country on such issues as accessibility, ease and safety provisions of various services in Banks for all persons with disabilities.
6. All meetings / consultations with respect to financial inclusion including those conducted by Bankers Committees at the State and District levels (SLBC & DLBC) shall include persons with disabilities.
7. Reserve Bank of India shall involve persons with disabilities in the consultation process on coins and currencies.
8. RBI shall issue exclusive master circular on financial inclusion of Persons with Disabilities in accessible formats.
9. A manual / handbook in accessible formats containing all relevant IBA and RBI circulars that afford equal access for persons with disabilities to banking services shall be prepared and widely circulated among banks & public. It should be included in bulletins and newsletters of banks.
10. All documents / policies / circulars / acts concerning banks shall be available in accessible formats.
11. All banks, financial institutions and offices shall comply with Universal design standards, which include ramps, railings, non slippery flooring, tactile directives, accessible toilets, urinal stalls with grab bars, lowered service counters, additional wheel chairs with appropriate specifications to ensure barrier free environment for all.
12. Accessibility strategies such as Bank’s procurement departments to check for accessibility of software/hardware from the IT companies shall be incorporated in all banks. IT industry forums such as NASSCOM shall be engaged with to ensure accessibility of technology at the design level.
13. Periodic access audits of banks, branches and ATMs shall be conducted by RBI appointed committees and access check clearance / points shall be awarded to banks that are accessible.
14. A centralised KYC registry inclusive of advance directives and specific requirements of people with different disabilities with built in safeguards shall be made available and accessible. Disabled people should be sensitized on the same. In case of modification of requirements / rules, persons with disabilities must be consulted and taken consent. (Advance directives should cover people without disabilities too in case of hospitalization & incapacitation, especially for people with psycho-social disabilities who have fluctuating conditions, people with dementia and other degenerating medical conditions and shall have an option of operation time where a person could choose to revive to his/her individual operations after a chosen period / situation / condition).
15. All debit / credit / transactions of account holders with high support needs, inter alia medical expense / payment of bills etc shall be paid by the designated support system / authority with the knowledge of the account holder with disability and all details of the transaction including its purpose shall be duly reflected in the monitoring mechanism of the bank and the concerned department. Complete monitory support should be provided by the state.
16. Banking should be promoted among all people with disabilities living in institutions.
17. For issuing of cheques in savings & current accounts, thumb impression shall be scanned and digitised.
18. Postal savings accounts as in practice currently shall be made available for all persons with disabilities.
19. All banks must create an Insurance policy to its account holders with disabilities as a safety measure.
20. All Persons with Disabilities and their Self Help Groups shall be included as one of the recognized priority categories among account holders / lending sectors /customers in banks, on par with other priority sectors.
21. The banks shall be mandated to maintain a database / statistics on customers for the category of all persons with disabilities / their Self Help Groups and each bank shall have an annual target to extend their products and services to all persons with disabilities, including persons with Psycho social / multiple disabilities and their Self Help Groups, which shall be duly monitored by appropriate authorities.
22. RBI shall incentivize private banks that have more number of consumers with disabilities and conduct programmes to sensitise personnel in all banks on how to deal with all Persons with disabilities in a befitting and dignified manner.
23. The MSJ&E and the Ministry of Finance shall instate a recognition award as part of its national awards for financial institutions offering comprehensive inclusion for clients with disabilities.
24. All rules, policies and laws governing the functioning of banks and other financial systems such as insurance policies, including the Contract Act should be amended in lines with and shall incorporate and mandate, within a time frame of not more than one year, the principles and provisions of the UN Convention on the rights of all persons with disabilities (UNCRPD), ratified by the Government of India in 2007.
25. There should be convergence among the different Ministries / departments and the RBI / banks with respect to the requirements to access welfare measures /poverty alleviation schemes and accordingly banks must design / make available and accessible its products and services to its account holders with disabilities.
26. RBI shall evolve a training module in consultation with appropriate ministry and stake holders on the various products & services provided by banks, their usage and specific provisions for persons with disabilities such as accessible banking and shall include the same in the financial education program provided to persons with disabilities.
27. There is a need to include a mandatory module on financial inclusion for clients with disabilities in the regular training programs of training institutes such as the Indian Institute of Banker’s Training and Bank internal trainings.
28. All Banks as also IBA in its list of proof of identity documents add Disability Certificate as a valid proof of identity.
29. Banks in collaboration with the marketing industry and the disability sector shall use market intelligence and promote schemes, products and services for persons with disabilities that would enable the financial inclusion, development and empowerment of persons with disabilities.
30. As part of CSR, Banks shall conduct studies in collaboration / consultation DPOs / NGOs on the issues / challenges faced by persons with disabilities, their guardians and bankers, and evolve an easier and safer system, which should be system / process based and not individual based that would enhance the quality of services and products delivered to its customers with high support needs.
PRODUCTS
1. The cheques issued by all banks shall comply universal design such as accessible bright colours, bright/big/thick print, specific Braille codes, etc to ensure accessibility for all including the elderly, people with low vision and intellectual disabilities.
2. Devices such as scanner with OCR screen reading combination, reading camera, etc shall be made available in all banks to enable persons with visual impairment to read the cheque contents before signing.
3. There shall be touch screen facility supported by a key pad / button system in ATMs. Thumb-print ATMs should be made available for easy access.
4. There shall be an option at the ATMs to choose for an extended time of operation, which could be 3-5 mins for those who require such support. In such case, an additional technical support mechanism for the safety of operation and a/c of the user shall be provided.
5. A talking machine that counts could be provided at ATMs.
6. There shall be accessible audio visual alarm system to safeguard oneself during attacks in ATMs.
7. Drive-in ATMs / banks should be promoted.
8. Separate Counters / Cells, mobile info / alerts, voice info / alerts, key board / button systems / Braille signage/ signage / service of sign language interpreter shall be introduced in banks/ATMs for easy and swift service of persons with disabilities.
9. Credit/debit cards with Braille embossed indicators shall be issued to persons with visual impairment. Details of credit/debit cards shall be issued in Braille / accessible formats.
10. Coins and currencies must be made accessible for persons with different disabilities.
11. Cheque Book facility shall be provided with no frill account for persons with disabilities.
SERVICES
1. All banks must adopt provisions that impact the full inclusion of persons with disabilities and issue such mandatory master circulars / guidelines to all the staff.
2. All bank officials shall be sensitized on the rights of and provisions for persons with disabilities in utilizing all services provided by the bank as well as a pro active approach towards persons with disabilities.
3. Persons with disabilities shall be provided all support that would facilitate immediate attention and easy operation / transaction to access all products and services in banks.
4. Customer service committees should be incorporated in all banks to facilitate access, communication between persons with disabilities and banks, maintain records of account holders with disabilities and to assist PWD s in banking.
5. One of the legal advisors/financial consultants in all banks shall be trained specifically to advise and assist persons with disabilities with respect to their operations with the bank as well as monitor/ensure safety of such operation.
6. In all Bank Customer Call Centres one seat shall be dedicated to addressing concerns and grievances of customers with disabilities.
7. Banking services shall be made available to children / minors with disabilities in par with children / minors without disabilities.
8. Parent/guardian/care giver of minors with disabilities shall be given the status of guardian and facilitated with banking operations in case of guardianship accounts as chosen by the individual.
9. The option of banking from home, through a bank executive who comes home to facilitate transactions, should be extended to cover all persons with disabilities in rural and urban areas.
10. Initiating accounts, extension of loans/subsidies and other transactions of Self Help Groups shall be facilitated by a mobile service / officials from banks navigating to villages / slums.
11. Internet banking and mobile banking shall be promoted to persons with visual /hearing /physical /intellectual /psycho social disabilities with a relaxation of rules in internet banking.
12. There shall be SMS/call alert/information to both account holders before and after each transaction in case of joint accounts and guardianship accounts of persons with disabilities.
13. Mobile /sms alert/information on all transactions should be provided as a free service for persons with disabilities. There shall also be an option to disown this service at one’s own will.
14. All ATMs shall have leveled flooring inside and outside along with accessible doors apart from other accessibility features.
15. ATM KIOSKS shall be provided on the road sides that would enable a person with disability sitting in a vehicle / wheel chair to operate and withdraw money without shifting his position / entering the ATM.
16. Road side ATMs with geo-locations must be made points of interests for persons with disabilities on open source maps (Eg Open Street Map) so that it could be easily identified by persons with disabilities. This will also help us check if banks comply with RBI's circular that asks for a third of ATMs within city limits to be made accessible.
17. Inexpensive but effective technological tools such as Bluetooth could be used by banks to send out constant messages to Bluetooth enabled devices that persons with visual impairment & other disabilities carry to indicate the availability of an ATM facility in a locality. This would be very useful for anyone who is on travel.
18. There shall be a person allotted to assist a person with disability including those with deaf blindness right from the entrance of the bank and also to help with the transaction if the individual with disability prefers to stay outside the bank (ATM).
19. Websites of all banks should be WCAG compatible to ensure accessible net banking for all.
20. Mobile Banking Applications and other technology solutions that the Banking industry comes up with on a regular basis shall be made accessible for all persons with disabilities.
21. Loan facility to Rare and long term disease / disabling medical conditions shall be enabled with no / low interest and long period of repayment. Example: loans for bone marrow transplantation, stem cell therapy etc. Loan facilities shall also be extended to persons with disabilities to purchase aids and appliances.
22. Banking services should be made available in the neighborhood in villages. Post offices both in rural and urban areas must be upgraded to provide all banking facilities in the neighborhood.
23. Separate grievance redressal system and personal assistance for persons with disabilities shall be made available in rural banks.
24. Safety provisions in banking should be made available for people with dementia, Alzheimers, other degenerating medical conditions, too, along with persons with disabilities.
CONCLUSION
1. Banks and all financial agencies must understand that creating access to products, services and delivery system aimed at the requirements of persons with disabilities will cut across the board and address the needs of all customers even if they change because of age, literacy, location from which they access, all public private financial arrangement / services etc and shall realize such access within a time frame of not more than one year to enable holistic social development, security and inclusion of all.
2. Towards such action and implementation, the Government of India in association with the Financial Ministry, the Ministry of Social Justice and Empowerment, the Department of Disability Affairs, the National Trust, the Reserve bank of India, the Indian Banks Association, the Rehabilitation Council of India and the Stake holders from the Financial & Disability Sectors shall conduct a national consultation on the financial inclusion of persons with disabilities and evolve a policy paper within the next three months and implement it.
Stakeholder List
Inputs received from:
1. People with Cerebral palsy, Hearing impairment, Visual Impairment, Orthopedic impairment, Spinal injury, Deaf blindness, Multiple Sclerosis, Muscular Dystrophy & Psycho Social Disabilities.
2. Parents of adults with Cerebral palsy, Autism, Mental Retardation & Multiple Sclerosis.
3. Participating Organisations / Activists:
➢ Disability Rights Alliance (DRA) - India
➢ EQUALS Centre for Promotion of Social Justice
➢ EKTHA
➢ Inclusive Planet Centre for Disability Law And Policy
➢ Vidya Sagar, Chennai
➢ The Banyan (Centre for women with psychosocial disabilities)
➢ Tamilnadu Federation for the Physically Handicapped Association
➢ State Forum for the Rights of Women with Disabilities
➢ Association for the Deaf, Chennai
➢ Organisation for Development Action, Trichy
➢ Amar Seva Sangam, Tirunelveli
➢ Organisation for Rare Diseases India
➢ Multiple Sclerosis Society of India, Chennai
➢ Mr. M. Pavan Kumar, CEO, Swadhikaar
➢ Mr. Vengal Reddy, CEO, Commitments Public Trust, Hyderabad
➢ Dr. Sam Taraporevala, Director, Xavier’s Resource Centre for the Visually Challenged
➢ Mr. Akhil Paul, Sense International
➢ Mr. Sudhakar Reddy, State Project Advisor, Disability Program, Govt of AP
➢ Ms. Sulochana, President, Vikalangula Federation, RR District, Telengana
➢ Ms. Vinoda, President, Vikalangula Federation, Khanmmam District, Telengana
➢ Mr.Gnana Bharathi, Spinal Injured Persons Association, Chennai
➢ Ms. Tulika Das, Director, SANCHAR, Kolkata
➢ Adv. Roma Bhagat, New Delhi
Enlighten Enterprises, ChennaiDlu South
Dear Smitha and friends,Thanks for sharing this comprehensive document. If not too late already, please do add Bapu Trust for Research on Mind & Discourse, Pune, as an endorser. Thanks!A point which I notice is that, 'guardianship' is not mentioned at all in the recommendations in one way or another except in the context of minors. I however suspect that there are a number of people, perhaps running in millions, who are already on guardianship arrangements with the bank either through a Trust (as happens in the case of persons with intellectual and psychosocial disabilities) or having their own account being run by their guardian. A point could be made concerning these, that such guardianship arrangements within banking system should be systematically studied, and actions taken in compliance with Article 12 of the CRPD. All people with disabilities have the right to enjoy financial independence.Best wishes,BhargaviIf a man does not keep pace with his companions, perhaps it is
because he hears a different drummer. Let him step to the music which
he hears, however measured or far away.
~ Henry David ThoreauBhargavi DavarAshoka FellowArts Based TherapistDirectorBapu Trust for Research on Mind & DiscourseWebsite: http://baputrust.org/
Dlu South
Dear Smitha and allThe document is overall comprehensive. However, a few questions. Who is its target audience, given the fact that there are parts like coins which RBI does not regulate, and insurance, which would also fall outside the pale of the RBI's responsibility.
Best Regards,
Dr. Sam Taraporevala
------------------------------------------
Director
Xavier's Resource Center for the Visually Challenged
(XRCVC)
St. Xavier's College, Mumbai - 400 001
s...@xrcvc.org
+91 22 22623298 (D)
+91 22 22620661-5 (B); extn: 366
+91 9869378436 (M)
+91 9967028769
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Vaishnavi Jayakumar
From: Roma Bhagat <romab...@gmail.com>
Date: Fri, Jul 4, 2014 at 1:35 AM
Subject:
To: Ajay Mehndiratta <ajay.meh...@gmail.com>, Ajay Mehndiratta <ajaym...@rediffmail.com>
Dear Col. Mehndiratta,
This is to inform you that I had attended the meeting on Financial Inclusion organized in partnership by the National Trust and SKOCH. There were different panels dealing with various aspects of the banking industry as well as the non – banking financial institutions and insurance companies.
On the afternoon of the 20th, there was a specific session devoted to Disability and Financial Inclusion where Amba Salelkar and Smita from Vidyasagar were among the people who spoke. In the morning I had intervened on the session on ‘Insurance and Banking’ to point out that disabled persons particularly those with mental illness were not given insurance or if some insurance company did give insurance it was at a higher premium and/or without the benefit of riders.
I had further pointed out that giving insurance to persons with mental illness should not be a problem for the insurance companies as any self inflicted injury or harm automatically resulted in non – payment of insurance. As such this risk evaluation did not lie in the realm of the insurance companies concerns it would be more appropriate for user – survivors or families of persons with psychiatric disabilities to evaluate the risks involved and take a decision on whether to opt for insurance or not.
I had also brought up the issue of bank accounts and pointed out that there was no prohibition in law but more a matter of construction and interpretation that denied persons with psychiatric disabilities the right to hold a bank account. In the afternoon session on disabilities Amba Salelkar had also spoken on the issue highlighting the fact that the Contract Act which was promulgated in the 1800s took into account the fact that persons with mental illness could have periods of lucidity just as persons without this disability could also be temporarily incapable of making rational decisions.
I had further raised the issue of reasonable accommodation for persons with mental illness with regard to PAN cards. I brought this up because in my capacity as a lawyer I have come across 2 cases where a person with mental illness had a problem with their PAN card and/or mode of delivery or the circumstances surrounding delivery. In one case that came to my attention the person had a problem with a particular numeral and since that numeral appeared in his PAN number he destroyed the PAN card. In another case the recipient who is otherwise highly functional believes that envelopes of a certain kind are weapons of bio – terror and he too destroyed his card, but the Department had reservations issuing a further PAN card.
I further brought up the issue of Banks and Insurance Companies forcing people to resign or terminating their services if they acquire a psycho – social disability during the course of employment even though Section 47 of the Persons with Disabilities (Equal Opportunity, Non Discrimination and Full Participation) Act, 1995 specifically prohibits government and all government bodies and authorities from dismissing any employee or denying him/her promotion or any other service benefits on the grounds of disability.
All these and some other points raised by other people in the audience as well as the panelists have been drafted and sent to Samir Kochar of SKOTCH for further dialogue in order to achieve some concrete results.
I hope this clarifies position. If you have any queries please do not hesitate to revert.
Regards,
Roma Bhagat
Dlu South
Mukul Inamdar pl check point 5 in services, Bhargavi check 31 under policy, Reshma – 4 in services, Jeeja – 2 in services, Roma / Vaishnavi – 16 & last 2 point in policy and insurance policy head in issues, Amar Jain – 18 under policy for the incorporation of your suggestions. Do read the entire document though.
Thank you all for all your inputs.
Warm regards
Smitha
Dear SmithaI understand your points. We should also in addition actually identify certain low-hanging fruits we can push for. Going the policy paper route could mean that we will be caught up in endless discussions and dialogue. Hence while I understand that chasing the low-hanging fruit option could result in the authorities granting some token concessions and then deliberately or otherwise dragging their feet I feel that such an approach from an advocacy perspective will help also in confidence-building. We would have to keep the pressure on even after certain initial inclusive steps are taken.
Best Regards,
Dr. Sam Taraporevala
------------------------------------------
Director
Xavier's Resource Center for the Visually Challenged
(XRCVC)
St. Xavier's College, Mumbai - 400 001
s...@xrcvc.org
+91 22 22623298 (D)
+91 22 22620661-5 (B); extn: 366
+91 9869378436 (M)
+91 9967028769
----------------------------------------
The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain proprietary, confidential or privileged information. If you are not the intended recipient, you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately and destroy all copies of this message and any attachments.
WARNING: Computer viruses can be transmitted via email. The recipient should check this email and any attachments for the presence of viruses. The Organisation accepts no liability for any damage caused by any virus transmitted by this email. www.xrcvc.org
From: Dlu South <dlu....@gmail.com>
Sent: Fri, 04 Jul 2014 16:10:09
To: "Dr. Sam Taraporevala" <s...@xrcvc.org>
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Subject: Re: Final Draft recommendations on financial inclusion
Dear Smitha and all
Dlu South
Issues in Operations in Banks / Financial
Institutions & Recommendations
Persons with disabilities including those with intellectual / neurological / psycho social disabilities / disabling medical conditions are denied all insurance policies (life, travel, medical, property, etc). Family insurance policies exclude members with disabilities among other family members and cover only those without disabilities in a family.
Persons with disabilities who somehow succeed in getting an insurance policy are charged additional premium, provided only base cover policy without death benefit, medical cover or other benefits of riders.
RECOMMENDATIONS
POLICY
1. All Banks and financial institutions must recognize that persons with disabilities have the right to respect to inherent dignity and any such act of the banker / banking system / documents including products and services inter alia use of language, gesture, etc that is in derogation to persons with disabilities amounts to inequality, discrimination and degradation of the account holder with disability.
2. All Banks and financial institutions must recognize that every person with disability has inherent capacity to access all products and services delivered by banks and other financial institutions.
3. All Banks / financial institutions as also IBA shall add the term ‘disability’ in their standard non-discrimination clause where it is mentioned that services will be offered to all without any discrimination based on caste/religion/gender etc.
4. Measures shall be taken to promote banking among disabled people in rural and urban areas, so that more disabled people open accounts and avail banking services as well as make banks aware of their responsibility to clients with disabilities.
5. A core committee on Banking services for persons with disabilities with adequate representation of persons with disabilities should be formed. The committee shall conduct periodic consultation with persons with disabilities across the country on such issues as accessibility, ease and safety provisions of various services in Banks for all persons with disabilities.
6. All meetings / consultations with respect to financial inclusion including those conducted by Bankers Committees at the State and District levels (SLBC & DLBC) shall include persons with disabilities.
7. The Ministry of Finance shall involve persons with disabilities in the consultation process on coins and currencies.
8. RBI shall issue exclusive master circular on financial inclusion of Persons with Disabilities in accessible formats.
9. A manual / handbook in accessible formats containing all relevant IBA and RBI circulars that afford equal access for persons with disabilities to banking services shall be prepared and widely circulated among banks & public. It should be included in bulletins and newsletters of banks.
10. All documents / policies / circulars / acts concerning banks / financial institutions shall be available in accessible formats.
11. All banks, financial institutions and concerned offices shall comply with Universal design standards, which include ramps, railings, non slippery flooring, tactile directives, accessible toilets, urinal stalls with grab bars, lowered service counters, additional wheel chairs with appropriate specifications to ensure barrier free environment for all.
12. Accessibility strategies such as Bank’s procurement departments to check for accessibility of software/hardware from the IT companies shall be incorporated in all banks. IT industry forums such as NASSCOM shall be engaged with to ensure accessibility of technology at the design level.
13. Periodic access audits of banks, branches and ATMs shall be conducted by RBI appointed committees and access check clearance / points shall be awarded to banks that are accessible.
14. A centralised KYC registry inclusive of advance directives and specific requirements of people with different disabilities with built in safeguards shall be made available and accessible. Disabled people should be sensitized on the same. In case of modification of requirements / rules, persons with disabilities must be consulted and taken consent. (Advance directives should cover people without disabilities too in case of hospitalization & incapacitation, especially for people with psycho-social disabilities who have fluctuating conditions, people with dementia and other degenerating medical conditions and shall have an option of operation time where a person could choose to revive to his/her individual operations after a chosen period / situation / condition).
15. All debit / credit / transactions of account holders /customers with high support needs, inter alia medical expense / payment of bills etc shall be paid by the designated support system / authority with the knowledge of the account holder with disability and all details of the transaction including its purpose shall be duly reflected in the monitoring mechanism of the bank and the concerned department. Complete monitory support should be provided by the state.
16. Reasonable accommodation measures for persons with psycho social disabilities and people with high support needs with respect to the utilization of all products and services under the purview of Ministry of Finance, including Banking, Insurance, Pan Cards etc shall be arrived at by banks and other financial institutions in consultation with Persons with psycho social disabilities / high support needs and the local disability network / appropriate authorities.
17. Banking should be promoted among all people with disabilities living in institutions.
18. For issuing of cheques through savings / current accounts / other business purposes, thumb impression shall be recognised, scanned, digitized and a centralised technological user friendly verification/safety mechanism shall be evolved and executed.
19. Postal savings accounts as in practice currently shall be made available for all persons with disabilities.
20. All banks must create an Insurance policy to its customers with disabilities as a safety measure.
21. All Persons with Disabilities and their Self Help Groups shall be included as one of the recognized priority categories among account holders / lending sectors /customers in banks, on par with other priority sectors.
22. The banks shall be mandated to maintain a database / statistics on customers for the category of all persons with disabilities / their Self Help Groups and each bank shall have an annual target to extend their products and services to all persons with disabilities, including persons with Psycho social / multiple disabilities and their Self Help Groups, which shall be duly monitored by appropriate authorities.
23. RBI shall incentivize private banks that have more number of consumers with disabilities and conduct programmes to sensitise personnel in all banks on how to deal with all Persons with disabilities in a befitting and dignified manner.
24. The MSJ&E and the Ministry of Finance shall instate a recognition award as part of its national awards for financial institutions offering comprehensive inclusion for clients with disabilities.
25. All rules, policies and laws governing the functioning of banks and other financial systems such as insurance policies, including the Contract Act should be amended in lines with and shall incorporate and mandate, within a time frame of not more than one year, the principles and provisions of the UN Convention on the rights of all persons with disabilities (UNCRPD), ratified by the Government of India in 2007.
26. There should be convergence among the different Ministries / departments and the RBI / banks with respect to the requirements to access welfare measures /poverty alleviation schemes and accordingly banks must design / make available and accessible its products and services to its account holders with disabilities.
27. RBI shall evolve a training module in consultation with appropriate ministry and stake holders on the various products & services provided by banks, their usage and specific provisions for persons with disabilities such as accessible banking and shall include the same in the financial education program provided to persons with disabilities.
28. There is a need to include a mandatory module on financial inclusion for clients with disabilities in the regular training programs of training institutes such as the Indian Institute of Banker’s Training and Bank internal trainings.
29. All Banks as also IBA in its list of proof of identity documents add Disability Certificate as a valid proof of identity.
30. Banks in collaboration with the marketing industry and the disability sector shall use market intelligence and promote schemes, products and services for persons with disabilities that would enable the financial inclusion, development and empowerment of persons with disabilities.
31. The Ministry of Finance in association with the Department of Disability affairs (with further collaboration / consultation with Banks & DPOs / NGOs) shall conduct systematic studies on the already existing guardianship arrangements within banking system and the issues / challenges faced by persons with disabilities, their guardians and bankers, thereby evolve and execute an easier cum safer system in compliance with article 12 of UNCRPD (All people with disabilities have the right to enjoy financial independence), which should be system / process based inclusive of all individual reasonable accommodations of all persons with disabilities that would as well enhance the quality of services and products delivered to customers with high support needs. The same shall be extended as CSR activities of banks / financial companies.
32. All Insurance policies shall be extended to all persons with disabilities as potential consumers on an equal basis with others. Measures shall be taken to promote Insurance among disabled people in rural and urban areas.
33. Banks and other financial institutions / Companies shall not force employees to resign or terminate their services if they acquire any disability including psycho – social disability during the course of employment or deny promotion and other service benefits on the grounds of disability.
PRODUCTS
1. The cheques issued by all banks shall comply universal design such as accessible bright colours, bright/big/thick print, specific Braille codes, etc to ensure accessibility for all including the elderly, people with low vision and intellectual disabilities.
2. Devices such as scanner with OCR screen reading combination, reading camera, etc shall be made available in all banks to enable persons with visual impairment to read the cheque contents before signing.
3. There shall be touch screen facility supported by a key pad / button system in ATMs. Thumb-print ATMs should be made available for easy access.
4. There shall be an option at the ATMs to choose for an extended time of operation, which could be 3-5 mins for those who require such support. In such case, an additional technical support mechanism for the safety of operation and a/c of the user shall be provided.
5. A talking machine that counts could be provided at ATMs.
6. There shall be accessible audio visual alarm system to safeguard oneself during attacks in ATMs.
7. Drive-in ATMs / banks should be promoted.
8. Separate Counters / Cells, mobile info / alerts, voice info / alerts, key board / button systems / Braille signage/ signage / service of sign language interpreter shall be introduced in banks/ATMs for easy and swift service of persons with disabilities.
9. Credit/debit cards with Braille embossed indicators shall be issued to persons with visual impairment. Details of credit/debit cards shall be issued in Braille / accessible formats.
10. Coins and currencies must be made accessible for persons with different disabilities.
11. Cheque Book facility shall be provided with no frill account for persons with disabilities.
SERVICES
1. All banks and financial institutions must adopt provisions that impact the full inclusion of persons with disabilities and issue such mandatory master circulars / guidelines to all the staff.
2. All officials and staff at all banks and all financial institutions shall be sensitized on the rights of and provisions for persons with disabilities in utilizing all products and services provided by banks / financial institutions as well as a pro active approach towards all persons with disabilities.
3. All Persons with disabilities shall be provided all support that would facilitate immediate attention and easy operation / transaction to access all products and services in banks and other financial institutions.
4. Customer service committees should be incorporated in all banks (urban, semi urban and rural), to facilitate access, communication between persons with disabilities and banks, maintain records of customers with disabilities and to assist Persons with Disabilities in banking. The Committees shall connect with local disability networks for additional guidance.
5. Powerful monitoring and grievance redressal systems / cells for persons with all disabilities shall be executed in all banks / financial institutions, including those situated in rural & semi urban areas.
6. One of the legal advisors/financial consultants in all banks shall be trained specifically to advise and assist persons with disabilities with respect to their operations with the bank as well as monitor/ensure safety of such operation.
7. In all Bank Customer Call Centres one seat shall be dedicated to addressing concerns and grievances of customers with disabilities.
8. Banking services shall be made available to children / minors with disabilities in par with children / minors without disabilities.
9. Parent/guardian/care giver of minors with disabilities shall be given the status of guardian and facilitated with banking operations in case of guardianship accounts as chosen by the individual.
10. The option of banking from home, through a bank executive who comes home to facilitate transactions, should be extended to cover all persons with disabilities in rural and urban areas.
11. Initiating accounts, extension of loans/subsidies and other transactions of Self Help Groups shall be facilitated by a mobile service / officials from banks navigating to villages / slums.
12. Internet banking and mobile banking shall be promoted to persons with visual /hearing /physical /intellectual /psycho social disabilities with a relaxation of rules in internet banking.
13. There shall be SMS/call alert/information to both account holders before and after each transaction in case of joint accounts and guardianship accounts of persons with disabilities.
14. Mobile /sms alert/information on all transactions should be provided as a free service for persons with disabilities. There shall also be an option to disown this service at one’s own will.
15. All ATMs shall have leveled flooring inside and outside along with accessible doors apart from other accessibility features.
16. ATM KIOSKS shall be provided on the road sides that would enable a person with disability sitting in a vehicle / wheel chair to operate and withdraw money without shifting his position / entering the ATM.
17. Road side ATMs with geo-locations must be made points of interests for persons with disabilities on open source maps (Eg Open Street Map) so that it could be easily identified by persons with disabilities. This will also help us check if banks comply with RBI's circular that asks for a third of ATMs within city limits to be made accessible.
18. Inexpensive but effective technological tools such as Bluetooth could be used by banks to send out constant messages to Bluetooth enabled devices that persons with visual impairment & other disabilities carry to indicate the availability of an ATM facility in a locality. This would be very useful for anyone who is on travel.
19. There shall be a person allotted to assist a persons with disabilities including those with deaf blindness right from the entrance of the bank and also to help with the transaction if the individual with disability prefers to stay outside the bank (ATM).
20. Websites of all banks / financial institutions should be WCAG compatible to ensure accessible net banking for all.
21. Mobile Banking Applications and other technology solutions that the Banking industry comes up with on a regular basis shall be made accessible for all persons with disabilities.
22. Loan facility to Rare and long term disease / disabling medical conditions shall be enabled with no / low interest and long period of repayment. Example: loans for bone marrow transplantation, stem cell therapy etc. Loan facilities shall also be extended to persons with disabilities to purchase aids and appliances.
23. Banking services should be made available in the neighborhood in villages. Post offices both in rural and urban areas must be upgraded to provide all banking facilities in the neighborhood.
24. Safety provisions in banking should be made available for people with dementia, Alzheimers, other degenerating medical conditions, too, along with persons with disabilities.
CONCLUSION
1. Banks and all financial agencies must understand that creating access to products, services and delivery system aimed at the requirements of persons with disabilities will cut across the board and address the needs of all customers even if they change because of age, literacy, location from which they access, all public private financial arrangement / services etc and shall realize such access within a time frame of not more than one year to enable holistic social development, security and inclusion of all.
2. Towards such action and implementation, the Government of India in association with the Ministry of Finance, the Ministry of Social Justice and Empowerment, the Department of Disability Affairs, the National Trust, the Reserve bank of India, the Indian Banks Association, the Rehabilitation Council of India and the Stake holders from the Financial & Disability Sectors shall conduct a national consultation on the financial inclusion of persons with disabilities and evolve a policy paper based on all the recommendations within the next three months and implement it.
Stakeholder List
Inputs received from:
1. People with Cerebral palsy, Hearing impairment, Visual Impairment, Orthopedic impairment, Spinal injury, Deaf blindness, Multiple Sclerosis, Muscular Dystrophy & Psycho Social Disabilities.
2. Parents of adults with Cerebral palsy, Autism, Mental Retardation & Multiple Sclerosis.
3. Participating Organisations / Activists:
➢ Disability Rights Alliance (DRA) - India
➢ EQUALS Centre for Promotion of Social Justice
➢ EKTHA
➢ Inclusive Planet Centre for Disability Law And Policy
➢ Vidya Sagar, Chennai
➢ The Banyan (Centre for women with psychosocial disabilities)
➢ Tamilnadu Federation for the Physically Handicapped Association
➢ State Forum for the Rights of Women with Disabilities
➢ Association for the Deaf, Chennai
➢ Organisation for Development Action, Trichy
➢ Amar Seva Sangam, Tirunelveli
➢ Organisation for Rare Diseases India
➢ Multiple Sclerosis Society of India, Chennai
➢ Bapu Trust for Research on Mind & Discourse, Pune
➢ Access India
➢ Blind Graduates Forum of India
➢ Mr. M. Pavan Kumar, CEO, Swadhikaar
➢ Mr. Vengal Reddy, CEO, Commitments Public Trust, Hyderabad
➢ Dr. Sam Taraporevala, Director, Xavier’s Resource Centre for the Visually Challenged
➢ Mr. Akhil Paul, Sense International
➢ Mr. Sudhakar Reddy, State Project Advisor, Disability Program, Govt of AP
➢ Ms. Sulochana, President, Vikalangula Federation, RR District, Telengana
➢ Ms. Vinoda, President, Vikalangula Federation, Khanmmam District, Telengana
➢ Mr.Gnana Bharathi, Spinal Injured Persons Association, Chennai
➢ Ms. Tulika Das, Director, SANCHAR, Kolkata
➢ Adv. Roma Bhagat, New Delhi
➢ Adv. Amar Jain
➢ Ms. Reshma Vallaippan, The Red Door/Mind Arcs, Pune
➢ Ms. Jeeja Ghosh, IICP
➢ Mr. Mukul Inamdar, PhD student, Centre for Mental Health Law and Policy
Shankar Subbiah S
With best regards,
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