重思高齡客戶的金融消費者保護手段

Rethinking Financial Consumer Protection Measures for Elder Customers

隨著我國人口結構老化，增加高齡客戶金融服務的需求，但亦可能因此衍生出一些潛在的行為風險，金管會於近年來雖試圖強化高齡金融消費者保護以及提升友善金融的措施，但本文認為，金管會目前係單純基於單一的年紀作為差別待遇的基準，並未完全針對高齡客戶於取得金融服務上所可能衍生的風險作更細緻的回應，反而可能造成不適當的年齡歧視，金管會及金融機構亦應特別針對客戶失智的狀況，針對我國具體的環境設定具體適當的指引，以期能更針對性地針對高齡客戶因為年紀增長所衍生的風險作適當的規範回應。

With the growing aging population in Taiwan, there is an increasing demand for financial services for the elderly. However, this may also lead to some potential behavioral risks. In recent years, although the Financial Supervisory Commission (FSC) has attempted to strengthen the protection of elderly financial consumers and improve friendly financial measures, this article argues that the FSC’s reliance solely on age as the basis for differential treatment lacks explanation and justification. The current measures also do not fully address the potential risks that may arise for elderly customers in accessing financial services. Instead, it may result in inappropriate age discrimination. The FSC and financial institutions should also focus on the situation of customers with dementia and establish specific and appropriate guidelines tailored to the specific environment in Taiwan. This is in order to respond more effectively to the risks that may arise for elderly customers due to aging, and to provide appropriate regulatory responses.