Responsible selling and marketing

Sales processes

In 2007, the Bank introduced the Important Information Document which provides customers with the key features of each of our products such as any charges applying and helpline details in a format that is easy to read and understand.

We are investing in a substantial initiative to standardise global customer documentation. The first stage is to simplify the account opening process for key transaction and lending products in our main markets. Efforts will continue throughout 2009 to standardise our global product suite.

Lending responsibly

By applying credit scorecards and credit bureau information, we can assess loan applications to ensure that we lend to people who can afford to borrow. These tools are critical to responsible lending as they allow the Bank to gain insight into the entirety of the customer’s financial commitments, including those outside the Bank. As such, they allow the Bank to make more informed decisions about the customer’s financial circumstances and ability to repay the debt.

A key element of ensuring appropriate credit controls is through continued engagement with regulators on increasing the use of credit bureaus. Credit bureaus are used in all countries where available, including Singapore, India, Hong Kong and South Korea. In countries where credit bureaus are not available, the Bank uses other methods such as requesting customers to declare their loans with other banks to assess their ability to service the debt.

Our lending book is often governed by loan-to-value (LTV) ratios set by individual country regulators which mean LTV ratios cannot exceed that considered appropriate by the state. Through our consumer credit assessment, we can achieve sustainable LTV ratios to ensure customers are not overextended.

Meeting customer needs

Product suitability assessments and explanation of product features, benefits and risks are embedded in the sales process for all investment products across both Consumer Banking and Wholesale Banking. These identify the customer’s and client’s financial needs and allow sales staff to meet those needs with appropriate financial solutions from the Bank’s range of products.

Across Wholesale Banking, the definition of appropriateness and suitability have been tightened up and the number of products that are being classified as complex or sophisticated, and as such, subject to audit approval, has been increased. In addition, the second phase of improvements will see random checks on appropriateness and post-sale checks on clients implemented.

In Consumer Banking, certain complex products may require a customer call-back from an employee who is independent of the sales process as a condition for distributing the product. The purpose of the call is to monitor sales quality and to confirm that the customer received a clear explanation of the features, risk and fees for the transaction.

Education and financial literacy

 Education and financial literacy

The Consumer Banking business in Singapore engages in consumer education programmes to increase customers’ financial literacy. It organised five investment seminars for its customers in 2008 on a range of investment topics.

Assisting vulnerable customers

Assisting vulnerable customersThe Bank has instituted specific processes to ensure that the Treating Customers Fairly principles are closely considered when undertaking sales of investment products to potentially vulnerable customers. The Bank has defined vulnerable customers as those with no prior investment experience and who are elderly or have limited formal education. A suitability assessment is conducted for all customers, taking into account their investment experience, age, risk appetite, concentration risk and other relevant factors. Where a customer is considered suitable, the product is sold with clear and transparent risk disclosure, including guidance that investors should be prepared to hold the investment to full term, and the potential risk of loss of investment capital in certain circumstances.


  • 20,267employees trained in Treating Customers Fairly
  • Investment seminars for customers held in Singapore
  • SMSalerts to help customers manage their accounts