Bank of Spain updates its Compendium of Good Practices with new criteria on disability support, consumer credit and heirs’ banking procedures

The Bank of Spain updated its Compendium of Good Banking Practices, adding new conduct criteria for banks’ interactions with customers with disabilities, consumer lending and procedures following a customer’s death, while also bringing the guidance into line with recent customer-facing regulatory changes. On disability, banks are expected to follow a framework protocol on support measures for the legal capacity of persons with disabilities under the universal accessibility principle and, in the event of a complaint, justify any deviation. It also sets expectations on recognising de facto guardians, including the use of a signed responsible declaration and, where relevant, additional documentation. On consumer loans, the Compendium states that early repayment or withdrawal should trigger reimbursement of the proportional part of the origination fee, and vehicle finance contracts should explicitly state whether any purchase discount must be repaid on early amortisation, with the financier bearing the burden of proving any loss in disputes. For heirs, banks should not condition the release of the deceased’s balances on settling other linked products or on heirs assuming loans, and where a new deed is required to subrogate heirs into debts they automatically assume, the bank should bear all formalisation costs. The update also clarifies the distinction between dormant balances and balances presumed abandoned after 20 years and transferred to the Treasury, noting that the six-year document retention period limits the information banks can provide to account holders.