Interview from AMCHAM TAIWAN《在台外籍人士的銀行惡夢Foreign Residents’Banking Woes》
編按：此為轉載文，本所蔡昆洲主持律師接受自由記者James Baron採訪，原文刊登於 AMCHAM TAIWAN
姓名學問大，這點到台灣的銀行辦事就知道，尤其你又是外國人的話。對長年居住在台灣的加拿大人潘龍泉（Anthony van Dyck）來說，原本只是例行的手續，卻因為他的名字太冗長而遲遲辦不成。
「我去同一家銀行快30年了，時間比每個行員在那裡的資歷還久，可是每年至少會有兩次碰到問題。」身為台灣加拿大商會理事的范達克說：「我的全名是John Anthony Christian van Dyck，很長。我的永久居留證用的是這個名字，所以銀行要求正式文件也要這樣。問題是，他們的電腦系統沒辦法打進這麼多字。」
In a system that relies on “self-regulation,” Taiwan banks are hesitant to lend their services to foreign nationals.
What’s in a name? When it comes to banking in Taiwan, quite a lot – especially if you’re a foreigner. For Anthony van Dyck, a long-term Canadian resident of Taiwan, an unwieldy name has proved a perennial hindrance to completing what should be routine procedures.
“I’ve been going to the same bank for almost 30 years – longer than any of the tellers have worked there – and at least twice a year there’s a problem,” says van Dyck, a director at the Canadian Chamber of Commerce in Taiwan. “My full name [with middle names], which is on my APRC, is a mouthful. They insist it should be like that on their official documents. The trouble is, their system doesn’t accept that many characters.”
Name-related fiascos feature prominently in expat gripes about banks in Taiwan. Andy, a British national who has worked as a teacher here for over a decade, recounts a “bureaucratic nightmare” with Taiwan Cooperative Bank (TCB) while trying to receive funds from abroad.
“My mother sent money using the Western style – given name, middle name, then surname,” he says. “They rejected the transaction on the grounds that the name didn’t match. This was pre-internet banking, so she had to trudge back to her bank and resend it according to the Chinese style, with the surname first.”
Following lengthy discussions with a TCB manager, Andy was able to add the Western version of his name to his account, alongside the Chinese format and the characters for his Chinese name. Shortly afterward, however, another remittance was rejected as it didn’t include his middle name. “I told them that this wasn’t required – even airline tickets don’t need the middle name – but they insisted on an exact match,” he says. “When I asked if I could add another option, they said two variations was the limit.”
Aside from a frustrating bureaucracy, foreigners frequently report problems with accessing financial products and services. Many banks in Taiwan still routinely refuse to issue credit cards to foreign nationals without a local guarantor, and the few that do often relent only after considerable pushback. Bizarrely, the local sponsor is seldom subject to a credit check and does not even need to provide any employment history.
There is no legal justification for this practice, says Phil Chen-Chang Tong, deputy director-general of the Banking Bureau at Taiwan’s Financial Supervisory Commission (FSC). Tong cites the “5 P’s principle” as the criteria that should be used to determine whether credit can be extended. The P’s refer to a person’s financial status, the purpose of the credit, the (re)payment sources, the protection (for the bank in terms of a borrower’s assets), and the perspective (of the borrower’s future resources).
“No matter whether you’re a foreigner or a local, banks should follow this principle,” says Tong. “Under our financial inclusion policy, no bank can have a regulation excluding foreigners.” However, Tong admits that “with more than 3,400 branches scattered across the island, there may be non-standard practices.”
Highlighting a February 9 press release reaffirming the FSC’s commitment to promoting a foreigner-friendly environment, Tong says FSC Chairman Huang Tien-mu has taken a hands-on approach to increasing the number of bank branches with bilingual facilities, application forms, and service counters with bilingual personnel.
“Each year, he picks one or two banks at random and visits their branches accompanied by the Minister of the National Development Council,” says Tong. “Last year, they visited Far Eastern International Bank and Bank of Taiwan to ensure their practices fulfill our expectations.”
FSC data from December 2022 puts the number of bilingual branches at 827 – an almost five-fold increase since the end of 2020, and an encouraging sign. However, other measures announced in the press release remain vaguely defined, consisting of directives to “improve” services but lacking concrete instructions on how to do so.
Elsewhere, FSC communication touts new provisions under the government’s Employment Gold Card Policy, which offers tax breaks and other benefits for “foreign professionals with financial expertise.” Four banks – Bank of Taiwan, First Bank, Huanan Bank, and Mega Bank – offer special services to Gold Card holders, including custom credit cards. However, these benefits cover only a small number of individuals – fewer than 6,000 at the close of last year – most of whom stay for a period of one to three years. Foreigners who have lived and worked in Taiwan for decades, including successful entrepreneurs and well-salaried employees, are not eligible for such incentives. On the contrary, many continue to be denied basic services available to almost any Taiwanese.
“Taiwanese banks are a bit xenophobic,” says Derek, a British business owner who has lived in Taiwan since 1994. As an example, “opening a business account required me sending in funds from overseas, which is just stupid,” he says.
Derek recalls being among the first foreigners he knew of in Taiwan to obtain a mortgage without a guarantor. He was flatly rejected when he first applied at the bank he had been using for years to receive his salary from the multinational financial institution he worked for. “No questions, no option to discuss,” he says. “My salary was plenty to cover the mortgage payments.”
Over the next couple of years, Derek approached a total of 14 local and foreign banks and received the same response. His final roll of the die was with a branch of an international bank that he heard might be more receptive to foreigners.
“I prepared well, with a PowerPoint presentation of my net worth, earnings, etc.,” he says. “Once again, the minions in the branch rejected me, but this time I insisted on seeing the manager. After I made my presentation to him, he finally agreed to give me a mortgage with no local guarantor, but with 50% cash down.”
That requirement would be beyond the means of many foreign nationals, and it was achieved only after causing “one hell of a fuss and being very annoyingly persistent, Derek says. In the face of such hurdles, most people simply give up, he notes.
Once again, banks were not playing by the rules. Taiwan’s laws on foreign nationals purchasing property are based on the principle of reciprocity. As such, there should be no barrier to getting a mortgage for those who meet the 5Ps, says FSC’s Tong.
Business owners can be hampered in other ways. Despite an amendment put forward by the Bankers Association of the Republic of China to regulations governing online services for foreigners, many foreign nationals still encounter obstacles with internet banking. The added insistence that business accounts be opened at the branch nearest the registered address of a business can make for some irksome experiences.
“As the foreign head of a company in Taiwan, I couldn’t get internet banking for at least six months,” says van Dyck. “The bank says it’s an anti-money laundering (AML) thing. After 27 years at the same bank, do they think I’m playing the long game, and now comes the cheat? An 18-year-old Taiwanese would be able to get this right off the bat.”
Elaine Salt, a pharmaceutical industry executive, tells a similar story. “I have money I’ve saved over the years in Entie Bank, and my sons have money there, too. All I want to do is transfer money between accounts, but they won’t give me internet banking,” says Salt. “They claim foreigners are not allowed, but Fubon Bank and HSBC give me internet banking, so Entie is just making it up.”
Another problem arose two years ago at Fubon Bank, where Salt has high-net-worth individual status. Hoping to avail herself of an arrangement that gives customers a 3% rebate on points earned with the Line communication app, she applied for a linked JCB card.
“I used to get Cathay Miles, but because of the pandemic I wasn’t flying, so didn’t need a card linked to an airline anymore,” she says. “The ridiculous thing is, I already have two cards with them. They know how much I earn, they know I own a house, plus they know I’m sending money overseas for my son’s school fees. They’re well aware of what liquidity is involved.”
Nevertheless, she was told by her personal banker that because she didn’t have a Taiwanese ID, she would need a guarantor. At one point, she was advised that her sons – for whom she still provides – could sign on her behalf. Following a “meltdown,” during which she threatened to close her account, Salt received a call approving her application later that afternoon.
Despite the launch of three digital banks – Line Bank, Rakuten Bank, and Next Bank – in the last two years, matters have yet to improve.
“We initially had high expectations for virtual banks, but we haven’t seen anything from them,” says Kunchou Tsai, a managing partner at Enlighten Law Group, which specializes in fintech. “On the contrary, they are simply trying to survive because there are still too many barriers, including AML regulations and requirements to conduct certain procedures physically.”
Hopes that major foreign fintech firms will enter the market are unlikely to be realized anytime soon, says Tsai. He mentions the London-headquartered firms Wise and Revolut as among companies that have approached Enlighten about accessing the FSC’s regulatory sandbox.
“After evaluation, they concluded that it would take too long – six months to a year – to get approval, and then another year in the sandbox,” he says. “After that, applying for your actual financial license could take a further year. For a fintech company, three years is a lifetime.”
While Tsai says money laundering is a legitimate concern, the real problem seems to be the FSC’s outmoded view of fintech – domestic or foreign – as simply a “tool provider” to complement existing institutions. “They don’t want these competitive foreign firms being disruptive to the market.”
This view is supported by a digital transition employee at a Taiwanese financial holding company. “They definitely try to protect native institutions’ interests,” she says. “But it’s also just a parenting attitude – trying to make sure that nothing goes wrong.”
Lu Pei-hua, a senior reporter with CommonWealth Magazine, believes the problem is partially rooted in Taiwan’s regulatory framework. “In some countries, they provide licenses that focus on specific services,” says Lu, who focuses on banking. “But in Taiwan it’s one full license for everything.” Granting access to the domestic financial market is thus seen as giving carte blanche to foreign firms.
However, like many others, Lu believes this old-fashioned mindset is just as aggravating for Taiwanese as it is for foreign residents. And Taiwanese with experience of banking abroad have their own personal nightmares to relate.
For Hou Mei-chen, a businesswoman from Miaoli County, opening an account in the UK in the 1990s turned into a decades-long ordeal to retrieve her remaining £500 balance upon returning to Taiwan. Relatives attempted to assist during a visit to London in 2003 but were told the account holder had to close the account in person. The money remains sitting in a Barclays Bank account to this day.
Hou’s experience compares unfavorably with that of her niece in Australia. “After she graduated from university in Perth and came back to Taiwan, she closed her account with a digital signature,” says Hou. “Because so many overseas students leave without closing accounts, Australian banks allow this.”
Monica Lai, an e-commerce product manager and former Citibank employee who lived in the UK between 2007 and 2012, has a slightly better impression of banking there. “Even back then, I barely went to Natwest,” she says. “Ninety-five percent of the things I needed to do could be done online or via phone.”
However, Carl Thelin, a Taiwan-born American filmmaker, corroborates Hou’s frustration in trying to close a UK bank account remotely. “Eventually I had to fly to London to negotiate a deal with the BBC,” says Thelin. “It ended up falling through, but my one consolation was I got to shut those damned accounts.” Still, Thelin says the UK remains only “the second worst banking system I have ever had the displeasure to experience.” Top spot, he says, goes to Taiwan “by some way.”
For his part, FSC’s Tong expresses regret at the problems foreign nationals face with banking in Taiwan. “I’m surprised and sorry to hear about these problems,” says Tong. He welcomes feedback, which he says will help improve the FSC’s “offsite supervision” through meetings with banking executives.
“We will let the bank CEOs know that our policies and practices need to be fine-tuned to pay more attention to such cases.”