Member

Finally, the group includes an amendment requiring banks to provide the Minister with the details of any deputy acting on behalf of an account holder when a relevant notice or order is issued. On its face, that is a sensible and practical improvement, ensuring that, where someone is represented, for example because they lack capacity or are otherwise vulnerable, the department has the information needed to communicate with their deputy directly. However, this also highlights a wider point. Where a deputy is in place, there is almost always a reason. A person may be unwell, may lack capacity or may simply be unable to manage their own financial affairs. It is therefore crucial that the department’s processes recognise and respect those circumstances. Contacting the deputy is not enough in itself. The system must also be sensitive to the reasons why the deputy exists and must handle such cases with the care and discretion they require.