Our commitment to senior customers
We value our senior customers
At Home Bank, we are here to offer support, so you can feel confident in your ability to bank no matter your age.
Home Bank shows our commitment to seniors by offering information and resources applicable to their unique needs and challenges.
Resources and information
Seniors Code Report
Home Bank values our senior customers and, as part of its commitment to support them, has adopted the Canadian Banker’s Association’s (CBA), voluntary Code of Conduct for the Delivery of Banking Services to Seniors.
The Code is based on seven principles that seek to identify and address the unique challenges that seniors may face when they access banking services.
Key among our commitments to seniors are:
- Ease of access to all our products and services.
- Reduction in the risks of financial harm from financial abuse and elder abuse.
- Protection from risks that seniors may face through training of employees to identify and mitigate such risks.
- Support for specific needs of seniors through provision of appropriate resources for employees to meet those needs.
This public report outlines the steps (details provided in the next section) Home Capital Group and its subsidiaries have taken to support the principles set out in the Code.
Details (Actions Taken)
The Company’s internal Seniors Code, which addresses the Principles of the CBA’s Code, was approved by the Executive Committee.
The internal Seniors Code and other policies and procedures address:
- Employee and management roles and responsibilities.
- Training of employees and representatives.
- Identification of circumstances where seniors may require additional assistance with their banking activities.
- Identification and escalation of incidents of suspected financial abuse and fraud of seniors.
- Incorporation of the Code into the Company’s regulatory compliance management framework.
- Continuous review of financial risks faced by seniors.
- Monitoring of customer complaints and fraud claims to identify trends and typologies of issues related to seniors.
Home Bank has implemented measures to facilitate effective communication with seniors, such as:
- Making customer communications available in formats that consider the needs of seniors; this includes making employees available to provide live assistance to seniors to help with navigation of our online services.
- Providing training to employees on formats and delivery channels that can be easily accessed by and are available to seniors.
- Continuously enhancing the presentation of information relevant to seniors in a consolidated location.
- Adherence to clear language principles to ensure that communications with all customers, including those directed towards seniors, are clear, simple and not misleading.
- Our websites are developed in keeping with the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA.
Home Bank’s client-facing employees completed initial training related to the Seniors Code prior to January 1, 2023. Refresher training is provided annually based on consultations with internal subject matter experts who maintain knowledge on trends and typologies. This year’s annual training includes content on:
- Detection and prevention of financial abuse and mistreatment, fraud and scams
- CBA’s Commitment on Powers of Attorney and Joint Deposit Accounts
- Available resources on matters relevant to seniors’ banking needs
- Escalation processes for complaints and reports of fraud, financial abuse or scams
Employees have access to training materials and the external website containing consolidated information and may escalate any concerns to members of management who have received additional training in the commitments set out in the Seniors Code, or directly to the Seniors Champion.
Our Fraud Department provides periodic updates to business units on fraud trends affecting all customers, including those specifically targeting seniors.
The Seniors Champion routinely engages with front-line business units to identify the needs of seniors and addresses those needs through the delivery of services.
Home Bank’s Seniors Champion works with Business Units to:
- Identify and document indicators of potential financial harm to seniors.
- Revise bank practices to improve the identification and prevention of financial harm to seniors, including an effective transaction monitoring program that identifies unusual transactions.
- Ensure that new products and services are reviewed for potential financial harm to seniors.
Although Principle 6 is not applicable to Home Bank because its products are offered through Oaken Financial’s retail locations, it will apply the spirit of the principle in any decision taken to close an Oaken retail location, or to withdraw its products from those locations.
Home Bank has published this 2023 Seniors Code Report to provide detail on the measures the bank takes to support seniors.
If you have any questions regarding this Report, or Home Bank’s practices with respect to serving our senior customers, please contact us.
Powers of Attorney and Joint Accounts
Definition: POA
A Power of Attorney (POA) for Property is a legal document that provides an Attorney (the person named in the document) authority over all or some of the grantor’s property (including finances).
POA allows the Attorney to manage the property on the grantor’s behalf for the grantor’s benefit.
POA can be “specific” or “limited,” where the Attorney is authorized for a limited task (for example, sell a house) or for a specific period (for example, for a period that you – the grantor – are expected to be out of the country).
The POA can be effective upon execution, or it can start on a specific date or occurrence provided for in the document.
The requirements for a valid Power of Attorney for Property differ from province to province (and over time). Care must be taken to ensure that all formalities with respect to the creation of the document and the relationship have been met in the particular jurisdiction (province, territory or foreign jurisdiction).
Definition: Attorney
An Attorney for Property is a fiduciary, who, regardless of the form of Power of Attorney, is obligated to act as a fiduciary to the grantor of the Power of Attorney and exercises his or her duties diligently, honestly and with integrity for the benefit of the person (and therefore, unless otherwise expressly provided for in the document creating the power, not for the benefit of the Attorney himself or herself).
Types of POA
ENDURING OR CONTINUING POA
An enduring or continuing Power of Attorney expressly provides that the Attorney shall continue to act for the grantor if the grantor becomes mentally incapable of managing their property (including your finances).
Depending on the terms of the document, an enduring or continuing Power of Attorney can take effect as soon as it is signed (such that it is effective while the grantor is capable of managing their property), or it may require some additional event (such as, losing capacity to manage property) to occur.
In such case a medical note, provided by a physician, may be required proving that the document is now in effect.
Important: In the absence of language in the document that the Attorney is to continue to act should the grantor become incapable of managing their property, the relationship between the grantor and the Attorney is terminated if the grantor becomes mentally incapable of managing their property.
POA FOR PERSONAL CARE
A Power of Attorney for Personal Care identifies and provides authority to the person you select to make personal care decisions on your behalf upon you becoming incapable of making such determinations on your own.
The Attorney for Personal Care does not have to be the same as the Attorney for Property.
Important: Home Bank and Oaken Financial do not take instructions from Attorneys for Personal Care.
Home Bank and Oaken Financial Requirements
Overview
Home Bank and Oaken Financial will accept a Power of Attorney for Property (POA) that meets the following requirements:
- It is for property. We do not take instructions from Attorneys for Personal Care.
- It meets the provincial, territorial or foreign requirements of the location where it was signed, including being signed by the grantor in front of the requisite number of qualifying witnesses.
- It is either the original document, or a notarized or certified true copy of the original. A photocopy is not accepted.
- If the authority is granted only as a result of the incapacity of the grantor, proof of incapacity is required by the document (i.e., one or more medical opinions).
- Where more than one Attorney is named, all the required Attorneys must sign all the required documentation.
- If an alternate Attorney wishes to act, sufficient proof should be provided for the original Attorney’s inability to act.
Attorney(s) Requirements
Do’s and Don’ts
WHAT CAN THE ATTORNEY(S) DO?
- Transact business respecting the grantor’s property in all areas specified by the grantor.
- Potentially act as the replacement trustee on an “in-trust for” account where the grantor of the POA was the original trustee, however, prior to doing so additional steps may be required.
WHAT THE ATTORNEY(S) CANNOT DO?
- Link their banking info to a client’s account.
- Open GIC in joint names (POA and Grantor). View POA grid for additional scenarios.
Transfer funds into joint name from the grantor to grantor and POA. - Change or assign designations on registered plans (regardless of what is in the documentation).
- Act as POA for the grantor in respect of his or her fiduciary role as an estate trustee, executor or trustee of a formal inter-vivo trust without further information and confirmation from Oaken Financial.
- Transfer funds into their account (even for stated “probate planning purposes”).
- Undertake transactions for a corporate entity owned by a grantor of a POA – these must be undertaken by directors or proper signing officers of the corporate entity and require different documentation providing for such directors and signing officers drafted by counsel for the corporate entity.
More than one Attorney (authorized signing authorities and the provision of instructions)
Joint or no designation
REQUIREMENTS
- All Attorneys must execute all documents and provide all the instructions together. No one (or majority) is allowed to act without consent from all of the other Attorneys.
- All Attorneys must complete any required know-your-client documentation.
Designated jointly and severally
REQUIREMENTS
- The Attorneys may make decisions together or act separately, subject to any additional restrictions in the documentation.
- All Attorneys must complete any required know-your-client documentation.
- Home Trust or Oaken Financial will be under no obligation to contact any other Attorney in the face of an instruction from just one Attorney.
Designated requires a majority
REQUIREMENTS
- A majority must sign all the documentation.
- All Attorneys must complete any required know-your-client documentation, subject to any additional restrictions in the documentation (such as, a particular person being required to be in the majority, like a spouse).
- Home Trust or Oaken Financial will be under no obligation to contact any other Attorney in the face of an instruction from the majority.
Documentation from Attorneys
In every case, the Attorney(s) must provide the following:
- A completed Authorized Signatory Form
- A completed Investment Application or Letter of instruction (signed by the required signatories)
- Proper identification (as per our processes)
Application requirements
- Investment application should be in the name of the registered owner.
- Investment cheque should be from the client.
Unacceptable POAs
Home Bank and Oaken Financial will not accept any POA that:
- is unclear.
- Is for personal care only.
- Is from another financial institution.
- Has been superseded by another document.
- Requires Home Bank or Oaken Financial to monitor the Attorney’s activity(ies).
Power of Attorney Issues and Questions
If your activities related to power of attorney do not meet Home Bank’s requirements, we may refuse to carry out your instructions and advise you of our reasons for doing so. If you disagree with our reasons or have additional questions, you may refer to our Complaint Handling Procedures on the Home Bank website.
Accessibility
At Home Bank we believe in creating an environment that is accessible for all of our existing and future clients, including those with disabilities. We recognize that people with disabilities may have different needs and we work hard to provide the same level of customer service to all of our clients by providing barrier-free facilities and services in our branches, offices and online.
Accessible customer service
Home Bank offers accessibility for visually and hearing-impaired clients, the elderly and persons with restricted mobility through:
- Acceptance of local telephone relay service.
- Deposit advisors who will meet with clients at their home, in their office or other agreed upon locations.
- Online banking through Oaken.com.
Service animals
Service animals assisting our clients are always welcome in our offices and branches.
Support persons.
A client with a disability can be accompanied by a support person, which may include conducting banking business or attending a meeting.
Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, Home Bank will provide notice of the disruption. The notice will be in a conspicuous location and will include information about the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if available.
Training of staff
Home Bank trains our employees on:
- Communicating with clients with various types of disabilities,
- Interacting with clients with disabilities who use an assistive device or require the assistance of a service animal or a support person; and
- Communicating and/or providing support to clients in a manner that is respectful of their disability.
Multi-year plan
At Home Bank, our multi-year plan outlines our strategy to prevent and remove barriers. In doing so, we are committed to providing a website that is accessible to the widest possible audience, which will include conforming to the standards of the Web Content Accessibility Guidelines (“WCAG”) 2.0 AA Standard by 2021.
This plan was reviewed in June 2019 and is scheduled to be reviewed again in August 2024.
*All resources are applicable for Home Bank, Home Trust Company and Oaken Financial.