A key focus for the FCA is supporting customers in vulnerable circumstances. The regulator’s Consumer Duty has put an additional spotlight on the issue.
Any of us could find ourselves in vulnerable circumstances at some point in our lives. In general terms, vulnerable customers may have additional or different needs that limits their ability or willingness to make decisions, or to represent their own interests.
The FCA identifies the following four key drivers of vulnerability:
- Health – conditions or illnesses that affect the ability to carry out day-to-day tasks
- Life events – such as bereavement, job loss or relationship breakdown
- Resilience – low ability to withstand financial or emotional shocks
- Capability – low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy, or digital skills.
Through our Client Engagement Hub, we can provide the support and tools for clients with vulnerabilities. Advisers know their clients best, so when they tell us that a client has particular vulnerabilities, or we identify a vulnerability, we can tailor our service to support their advice proposition for good outcomes. Importantly, we look to make processes for vulnerable people as effortless as they are for anyone else.
Adapting our support service to meet clients’ needs
With training, the skills to identify vulnerabilities are embedded across our Client Engagement Hub. We also have a team of dedicated specialists who can provide the additional help needed when a client with a vulnerability is identified. All details are logged so when the client contacts us again, the team member is already aware of their needs and can swiftly adapt how the interaction is conducted.
As our Client Engagement Hub is powered by advanced technology, it allows us to collect and analyse data to help us identify the common vulnerabilities of different demographics. It means we can better tailor our service to their needs and make better informed decisions on their behalf.
We have a range of accessibility tools available which we’re actively increasing the awareness of by promoting the services online.
For example, some of our documentation and outputs can be translated into braille or large print for the visually impaired. For those who are hearing or speech impaired, we can be contacted on the phone via Relay UK, which is accessible by computer, laptop, tablet or android smartphone. The service is confidential and enables users to type what they’d like to say, which is then relayed through to us in real-time.
We can also accept calls if a customer is using a registered Sign Language Interpreter to speak on their behalf.
Working in partnership with advisers
Our support for vulnerable customers is more than about our processes. Our approach is flexible and human to help advisers become much more familiar with the whole spectrum of vulnerabilities, and adapt their service as needed to an individual’s circumstances to ultimately deliver good outcomes for them.
Looking ahead, our aim is to work more collaboratively with advisers to share information on customers with specific needs. This means working in partnership with advisers, encouraging them to share details of clients’ vulnerabilities with us at an early stage, so we can proactively signpost vital services for their vulnerable clients.
Harnessing the data we collect, we’re currently identifying third parties we can engage with to help further support advisers and their clients with vulnerabilities. And we’re continuing to work hard to understand all types of specific needs our customers have.
Training, technology and collaboration
With the FCA’s Consumer Duty coming into force at the end of July, the need to have clear actions and good outcomes at every stage of the customer journey has never been more important.
But best practice isn’t just a regulatory imperative – it’s the right thing to do.
With our proactive focus on training, technology and collaboration, our goal is to lead the way, as vulnerability could affect anyone at any time; a person who’s not vulnerable today could be vulnerable tomorrow.
In the past, there have perhaps been knowledge gaps across the industry about how best to support those who find themselves in a vulnerable position. But by working together, sharing information and best practice, we can help advisers to deliver the good outcomes that clients with vulnerabilities deserve.
The value of investments can go down as well as up and your clients could get back less than they paid in.
The views expressed in this blog should not be regarded as financial advice.