The Economic Abuse Evidence Form (EAEF) is an information-sharing tool. It provides a single mechanism through which qualified money/debt advisors (trained by Money Advice Plus and Surviving Economic Abuse) can tell an organisation that an individual has experienced economic abuse.
In the EAEF, the qualified money/debt adviser will explain the impact of the economic abuse on the victim-survivor. The EAEF provides a clear and controlled format for this information. If an adviser contacts the financial services firm with a recommended action on behalf of the client, the firm has the supporting information needed to respond.
The Economic Abuse Evidence Form was devised by Money Advice Plus (MAP) and piloted in partnership with Surviving Economic Abuse (SEA).
“We want our customers to feel supported and listened to without them having to repeat their lived experience by having upsetting conversations. The EAEF allows for this, as all the information that we need can be found on the form. We want our customers to feel heard and have the opportunity to move forward with their life. I truly believe that the EAEF allows our customers to move forward with their banking and financial freedom knowing that they have been heard.”
Amy Sager, Senior Borrowing Lead, Monzo
The EAEF has major benefits for both victim-survivors and financial services firms:
"Lloyds Banking Group is dedicated to supporting customers impacted by financial and economic abuse. One of the ways we support victim-survivors is through our involvement in the ongoing pilot for the Economic Abuse Evidence Form (EAEF). This initiative is specifically tailored to assist victim-survivors by providing a way for them to only tell their story to creditors, financial services and other service providers once. This ensures that a victim-survivor avoids the need to repeatedly recall and share their experience. Having been part of the EAEF pilot since July 2021, we continue to see positive outcomes for our customers, and we look forward to continuing to support this initiative."
Lloyds Banking Group
The EAEF includes:
The EAEF is submitted with:
The qualified money/debt adviser will inform you if the client’s safety would be at risk if your organisation disclosed their address to anyone else. The person who understands the risk best is the victim-survivor, and the adviser will have discussed this directly with them.
The EAEF can only be used by money/debt advice organisations authorised by Money Advice Plus (MAP) and Surviving Economic Abuse (SEA).
Within those authorised organisations, the EAEF must only be completed and submitted by qualified money/debt advisers trained in economic abuse by MAP and SEA.
Money Advice Plus
PayPlan
Rethink Mental Illness
Citizens Advice (Plymouth)
Salford City Council Debt dpt
Wrekin Housing Group
Anglia Care Trust
Homemaker Southwest (and Money Advice Plymouth)
Gemap & Rethink Mental Illness
AdviceNI
The EAEF is currently being used alongside requests linked to coerced debt where the customer has experienced domestic abuse, including economic abuse.
Participating debt advice organisations must all provide a long-term casework service.
When an EAEF is submitted, the client will have received a comprehensive and holistic money/debt advice session. The qualified money/debt adviser will act in accordance with Financial Conduct Authority (FCA) regulations* and apply their economic abuse expertise.
The adviser will explain what options the client has for regaining control of their financial wellbeing. They will consider all their debts and explore the most appropriate debt management solution with their needs and safety at the heart of the process.
Once the client has decided which outcome they would like to pursue, the adviser will, when appropriate, submit the EAEF, Request Letter and Letter of Authority on behalf of the victim-survivor.
Assigning the same qualified money/debt adviser for the duration of the customer’s casework helps build rapport, trust, disclosure and client engagement.
Many money/debt advice services only operate one-off advice or ‘self-help’ models of advice (e.g. Money Advice Trust, StepChange). These services won’t be using the EAEF and would need to refer victim-survivors of economic abuse into a money/debt advice service that offers long-term casework delivered by economic abuse specialists.
“I appreciate your support so very much. Finding you and the organisation, was the start of ME again and ME being in control of my life again.”
(Victim-survivor supported by a participating debt-advice organisation)
Training is an essential part of processing the EAEF. The training equips participants with an increased understanding of what economic abuse is, how to spot the signs, and an understanding of the EAEF.
The EAEF training course is one full day, delivered online, from 10:00 – 16:00; split into two sessions (morning [10:00 -13:00] and afternoon [14:00 – 16:00])
Our recommendation is to send a small number of colleagues who will be responsible for receiving, actioning and making decisions about the ‘ask’ in the Request Letter accompanying the EAEF. Currently Request Letters supported by an EAEF are for unsecured debts only.
Attendees could be colleagues from:
The cost of the course is £375 + VAT per person for the full day or £250 + VAT per person for the afternoon only.
Colleagues that have attended SEA’s economic abuse training are able to attend the afternoon EAEF part of the training course only.
“The course gave me great awareness and I was shocked and horrified at the level abusers will go to control a victim. A very sobering day but has given me great insight and knowledge and the testimonials from victims will stay with me for a long time”
Training participant
“Although uncomfortable in some areas but not in a bad way. It [the course] opened my eyes more and will impact the way I personally manage victims of economical abuse. Thanks for offering such high-end training on a very difficult subject.”
Training participant
We ask firms using the EAEF to adhere to the following protocol:
Section 7 of the EAEF will indicate if the customer is happy to be contacted directly by the firm. The Consumer Duty (9.14) and Financial Abuse Code (3iv) support the right of victim-survivors to choose to give authority to an appointed representative to act on their behalf. If a victim-survivor has appointed a money/debt adviser as their representative, please do not contact the customer directly.
One of the most significant barriers victim-survivors of abuse face is not being believed. In some cases, it may be difficult to prove that an individual is acting under duress as coercive behaviour often takes place in private rather than in a bank, at a cashpoint or at a point of sale. Although abuse has taken place there is often not enough evidence for prosecution. Believing a victim-survivor’s story can bring hope and relief to someone who lived in fear that they would not be believed and has had the courage to share their story.
Money/debt advisers completing the EAEF are highly trained and qualified professionals. They have knowledge of economic abuse through training delivered by economic abuse specialists MAP and SEA.
When a victim-survivor comes to an adviser, they will share detailed information about the domestic abuse, including economic abuse, they have experienced. They will share verbal testimony and may also bring evidence of the abuse through photos, witness statements, text messages or bank statements.
The form will provide an appropriate level of evidence in one place. It will reference any supporting evidence that the debt adviser has seen (such as police reports, crime reference numbers, successful prosecutions etc.) but these will not be sent with the form.
We ask creditors not to refuse a request on the grounds of a lack of these types of formal evidence. Financial services firms do not need to receive detailed information evidencing the abuse. The EAEF acts as verification that the economic abuse has occurred as it is the qualified debt adviser who sees, reviews and verifies this information. We ask you to trust their professional judgement grounded in the organisations FCA* regulation, accredited quality standards and debt advice qualifications.
Please acknowledge receipt of the form within 7 days so that the qualified money/debt adviser can let the victim-survivor know the form has been received. This helps to manage customer wellbeing. We ask that you respond to the accompanying request within 6 weeks, although we understand that some decisions may take longer.
It’s best to keep the money/debt adviser informed if you think the process will take longer than 6 weeks. Money/debt advisers are asked not to contact your organisation again as long as they have received acknowledgement the form has been received.
If your organisation has not reached a decision within 6 weeks, the debt adviser will follow up asking for a response within the next 4 weeks.
The form has been carefully designed to include the right information. During the pilot, only 15% of forms required a firm to request additional information.
The EAEF means that requesting medical evidence, police reports or personal statements is not necessary or proportionate. Standard financial statements are not necessary, as they are unlikely to reveal the coercive and controlling behaviour a victim-survivor has experienced. It is also not always appropriate to ask victim-survivors who have experienced restriction, exploitation and/or sabotage of their finances to give detailed explanations to each firm on individual transactions. In the context of an abusers’ coercive and controlling behaviour, asking a victim-survivor to explain individual transactions may be highly retraumatising.
Whilst we understand all forms will be reviewed on a case-by-case basis, we would ask firms to carefully consider the impact on the victim-survivor of additional requests for information and whether they are necessary and proportionate. If you do require additional information, please contact the money/debt adviser in the first instance.
The EAEF will be accompanied by a Request Letter with details of the request being made and the debt solution the money/debt adviser is asking for. Where the Request Letter recommends a particular request (for example a debt write-off), we understand decisions will remain voluntary, case-by-case decisions for firms. If a request is not accepted, please communicate a reason for the refusal to the nominated money/debt adviser.
If the money/debt adviser and/or the customer is not satisfied with the response they receive, they may ask that your organisation further explain your position in writing. If the adviser does not receive a reply within 4 weeks, they may use your organisation’s regular complaints procedure.
If they or their client are still not satisfied with your firm’s response, they may pursue a complaint to the Financial Ombudsman Service (FOS). We ask firms to fully cooperate with this process by explaining their complaints procedure and providing the paperwork needed to complain to the FOS. Debt advisers will strive to work positively with firms throughout the case.
One of the aims of the EAEF is to safeguard firms’ staff by preventing them from being exposed to distressing descriptions of abuse or even photographs of injuries sustained.
However, there will be some brief accounts of abuse within the EAEF and, for this reason, we ask firms receiving the form to ensure that appropriate support is in place for the colleagues who will be working with the form. This could include additional supervision, debriefing, learning or reflection sessions or an employee assistance programme which provides counselling.
It is important for participating money/debt advisers to know where the form should be sent and that it is received by a team trained to use the EAEF. We ask that firms use a consistent or dedicated email address for money/debt advisers to send the EAEF, Request Letter, and Letter of Authority. You will need to confirm the email address you are using for EAEF submissions when you book onto the training.
This is up to your firm to decide. However, we recommend that you start receiving the form within 8 weeks of your training, to ensure that new skills and knowledge acquired are retained. We will ask you to confirm your start date for receiving the EAEF when you book onto the training.
Debt advisers follow FCA’s guidelines* for debt counselling firms to check a client’s identity. They also explain to clients how and what the data collected will be used for, confidentiality and data protection arrangements.
Financial services firms can be sure that the qualified money/debt adviser has obtained consent and shared their data privacy notice with the customer as part of being regulated by the FCA and Information Commissioners Office (ICO)*. The EAEF is always sent with a Form of Authority signed by the client, giving explicit consent to share their information. How financial service firms then process and hold data will be for them to determine, including retention or deletion of any documentation, following their own legal basis, guidance and GDPR rules.
The EAEF contains personal data, specifically identity information – name, date of birth and address of the client. The form also contains special category data (disclosures of domestic abuse, including economic abuse). Money/debt advice services process client’s data under ‘legitimate interest’. All money/debt advice services have their own databases, case management software or customer relationship management systems (CRM) to securely record client information and carry out case management.
For some victim-survivors, a good outcome requires appointing a representative to act on their behalf. The Consumer Duty (9.14) and Financial Abuse Code (3iv) support the right of victim-survivors to choose to give authority to an appointed representative to act on their behalf. The EAEF will indicate if the customer is happy to be contacted directly by the firm.
We understand that firms will want to offer consistent support to victim-survivors whether they have the support of a money/debt adviser or not. We would therefore encourage the firm to do all they can to support the victim-survivor. Debt advice may not be necessary. However, the firm should explore if the customer has more debts to other organisations. If the customer discloses that they have multiple debts with several firms, they are likely to need independent debt advice which may result in the EAEF being used to share information with each creditor to help the victim-survivor avoid telling their story multiple times.
The FCA handbook recommends firms sign post to free, independent debt advice. If your firm is interested in setting up a signposting or referral pathway to a specialist service, please let us know when booking onto training. Money Advice Plus will contact you to discuss your needs.
Most firms have indicated that they would prefer training to be for their own firm only. For a session to run for your firm only, there will need to be a minimum of 8 people (maximum of 16). If a firm is training less than 8 colleagues, you can book one of the ‘individual booking’ courses available, where you will learn alongside peers from other financial services firms. We strongly recommend firms put forward a minimum of 2 colleagues for training to account for circumstances such as annual leave, sickness or resignation, so that EAEFs are not left unprocessed and the customer waiting for a response.
The EAEF is an information sharing tool so has a range of potential future applications. Money and debt advisers are not regulated to give financial advice, which includes mortgage advice. However, we agree there could be benefits for the information within the EAEF to be shared with the mortgage provider. It would give the mortgage provider the whole picture of a customer’s circumstances that they may have been unaware of. Sending the EAEF to a mortgage provider has not been tested as part of the pilot and we would welcome the support of firms and their feedback.
Customers do not sign the EAEF directly as the debt adviser fills out the form and it is not shared with the customer to complete or edit. There are two reasons for this: Firstly, some clients will find it traumatising to read the written information. We have explained in the debt adviser training that it is best practice to share the wording that is written in the EAEF with the client. However, we need to be mindful that the client may not want to see this. Secondly, if the form is sent to the client, then it would be accessible to the public and may be used/sent to firms by a member of the public or by an organisation that doesn’t have the necessary training to use the form in the way it has been designed/intended to be used. This would mean the EAEF could be misused.
*All participating debt advice organisations are regulated by the FCA with the exception of one Local Authority Debt Advice team who operates under relevant Local Authority rules and regulation.