Government Equalities Office - Banning Age Discrimination
Credit unions and the age discrimination proposals
We have no objection in principle to the proposals as set out. In fact, we commend the efforts made to balance the elimination unjustified age discrimination with the beneficial and justifiable use of age as a risk-factor in pricing structures.
The exemption for financial services as proposed is a reasonable and logical step to avoid undermining financial systems. An inability to use an obvious risk-factor such as age when constructing price matrices would erode the ability of financial services to perform their distinctive economic function. Assessment and pricing of risk is one of the key fundamentals underpinning financial services without which the industry in general would be unable to function to the detriment of society which benefits greatly from services such as the supply of credit to the economy or insurance against unforeseen events.
Similarly, we agree that without a formalised and transparent structure under which the assessment of a risk factor such as age is carried out there is the potential for consumer detriment. This is true both where the consumer feels that they are being arbitrarily excluded from services or offered them only at higher cost, or where – because of a lack of transparency – firms could attempt to justify discriminatory practices behind unproven assertions that older or younger people pose a greater risk. As entities committed to providing inclusive financial services, credit unions are keen to see all groups fairly served by the financial services industry and to benefit from its support.
We do, however, have some concerns which relate to the proportionality of the proposals and their effect upon smaller entities operating within financial services. Credit unions are small organisations with limited resources.
The full response can be downloaded on the right hand side of the screen.