Vulnerable Customers Test Papers and Answer Sheets | Assessment and Quiz Answers | Categories and Definitions | Template for FCA Applications and Authorised Firms

1 Test Paper Overview

Testing, assessing and training employees in the regulatory compliance rules and standards is an essential business practice to ensure compliance, evidence competency and support your staff. We have designed a range of exclusive compliance assessment quiz and answer documents, with a view to assisting regulated firms in the compliance expectations.

1.1 Assessment Quiz & Answers

Our ready-to-use question and answer assessments come with beginner, intermediate and advanced style questions on the specific compliance areas and through detailed and expertly developed answers sheets, also aim to teach as well as test. The assessments are unique in that they do not just provide yes/no answers to the questions. Our compliance experts have provided detailed, relevant and compliant answers to each question so that gaps and understanding can be filed, and staff supported.

Assessments should be a continual part of any organisation and delivered as part of induction programmes, after training and on a rolling basis as part of a standard compliance regime. These assessments allow you to evidence your compliance to the Training and Competency requirements set by regulators and enable the identification of misunderstood areas, before they become a problem.

1.2 Using the Assessment

You are free to edit and use the document however suits your business type and needs, however we would suggest printing the quiz for hard copy use and then using the answer paper to mark the assessment and discuss the answers with the employee where gaps have been identified. You should also add a copy of the assessment and any marking/evaluation logs to the employees training file for future reference and compliance evidence.

1.3 Marking Sheet

Each of the questions come with a marking guide which can be used by the employee to know how many points/answers should be given, and for the marker to score the answer correctly. At the end of the document, you will find a marking sheet to make scoring the tests easier.

2 Vulnerable Customers Test Paper 1

You have 30 minutes to complete the quiz on Vulnerable Customers. This quiz has been designed to test your knowledge and understanding in this compliance area. Please make sure that you read each question carefully – the marks available for each question are noted on the bottom right.

1) Fill in the blanks on the below 2 Vulnerable Customer definitions: –

‘Customers who are _________, for whatever reason, to make an _________ decision at the

time of dealing with them’

‘Customers whose _________ (financial, mental or physical) could be put at _____ through

choosing the service or product you offer’

                                                                                        (4 marks)

2) What does MALG stand for?

________________________________________________________

                                                                                        (1 mark)

3) The Mental Health Act is applicable to dealing with vulnerable customers?

a. True                                                                         ___
b. False                                                                       ___

                                                                                        (1 mark)

4) The Vulnerable Customer ethos goes hand in hand with?

a. Information Security                                                 ___
b. Selling products & services                                     ___
c. Treating Customers Fairly                                       ___

                                                                                        (1 mark)

5) Name 3 categories of vulnerable customers: –

________________________________________________________

________________________________________________________

________________________________________________________

                                                                                      (3 marks)

6) You should always terminate a call once you realise that a customer is vulnerable?

a. True                                                                         ___
b. False                                                                       ___

                                                                                        (1 mark)

7) A customer mentions to you that her Husband recently passed away. Do you: –

a. Offer your sympathy and carry on with the call as normal  ___
b. Advise them that you are now unable to carry on with the call as they have identified themselves as being vulnerable  ___
c. Offer your sympathy and proceed at a slower pace, ensuring the customer understands what you are discussing and that they can make decisions at this time  ___

                                                                                        (1 mark)

8) List 2 things that you could do to help a vulnerable customer: –

________________________________________________________

________________________________________________________

                                                                                        (2 marks)

9) I don’t speak to customers on the phone or face to face so learning about vulnerable customers is not applicable to me or my job role.

a. True                                                                         ___
b. False                                                                       ___

                                                                                        (1 mark)

10) The customer you have been speaking to has agreed to the product/service that you are offering but has displayed signs of being hard of hearing throughout the conversation.

What could you do to ensure that their vulnerability has been noted and addressed?

a. Send everything you have discussed out in writing to the customer and sign them up after they have had time to read through everything  ___
b. Nothing, they have agreed over the phone, so must have heard what you were saying  ___
c. Ask to speak to another member of the family and disclose everything you have discussed with the customer to see if the family member agrees also  ___

                                                                                          (1 mark)

You have reached the end of test paper 1

3 Vulnerable Customers Test Paper 2

You have 30 minutes to complete the quiz on Vulnerable Customers. This quiz has been designed to test your knowledge and understanding in this compliance area. Please make sure that you read each question carefully – the marks available for each question are noted on the bottom right.

1) List 2 FREE debt counselling providers whom a vulnerable customer can be referred to: –

________________________________________________________

________________________________________________________

                                                                                        (2 marks)

2) Which of the below could be a sign of a customer’s vulnerability?

(Multiple answers accepted)

a. Confusion and misunderstandings
b. Speaking quite fast
c. Asking you to repeat most things that you have said
d. Being very decisive

                                                                                        (2 marks)

3) List 1 verbal and 1 written indictor that a customer may be vulnerable?

________________________________________________________

________________________________________________________

                                                                                        (2 marks)

4) Who/What are the Money Advice Liaison Group?

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

                                                                                        (3 marks)

5) List 3 mediums that can be used to communicate with a customer to reduce any misunderstandings?

1. ________________________________________________________
2. ________________________________________________________
3. ________________________________________________________
                                                                                 (3 marks)

6) You cannot sell a vulnerable person a financial product or service/ask them to donate money?

a. True                                                                         ___
b. False                                                                       ___

                                                                                        (1 mark)

7) What does Signposting mean?

_______________________________________________________________

_______________________________________________________________

                                                                                        (2 marks)

8) Why is summarising important?

 _______________________________________________________________

_______________________________________________________________

_______________________________________________________________

                                                                                        (3 marks)

9) If you identify someone as being vulnerable, you can deal with a third-party on their behalf without asking permission?

a. True                                                                         ___
b. False                                                                       ___

                                                                                        (1 mark)

10) What is a Debt & Mental Health Evidence Form?

a. A form an individual completes to see if they have debt and/or mental health issues
b. A form used by healthcare professionals, debt advisers and creditors to more effectively evaluate debtor circumstances and arrive at informed decisions
c. A form used by firms to decide if those in debt can apply for more credit

                                                                                        (1 mark)

You have reached the end of test paper 2

4 Vulnerable Customers Assessment Answer Sheet 1

Below are the answers to the first assessment test paper; the correct answer is provided in red underneath each assessment question. We have then provided detailed information about the question and answer which should be relayed to the assessment taker where any gaps have been identified. Use the mark guidance for scoring each answer.

1) Fill in the blanks on the below 2 Vulnerable Customer definitions: –

‘Customers who are unable, for whatever reason, to make an informed decision at the

time of dealing with them’

‘Customers whose welfare (financial, mental or physical) could be put at risk through

choosing the service or product you offer’

Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These customers may struggle to decide on whether the service or product you are providing is in their best interests.

Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product you offer – these customers include anyone who is going to be put at detriment from taking up your offer. This could be financially if taking out a loan or setting up a payment plan causes them to add financial stresses.

The financial regulator (the FCA) defines a Vulnerable Customer as “Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

2) What does MALG stand for?

Money Advice Liaison Group

MALG is a Forum working for greater and better communication, best practice, understanding and professionalism among organisations with an interest in personal debt. Their aim is to promote better communication, best practice, understanding and professionalism among organisations operating on a national level concerned with people in debt, debt advice, debt collection and all related ancillary matters within the UK.

Staff who may encounter vulnerable customers, are provided access to the Money Advice Liaison Group (MALG) website (http://www.malg.org.uk/debtmentalhealth.html) so that they can gain a better understanding of the issues faced by vulnerable customers in relations to money and debt.

3) The Mental Health Act is applicable to dealing with vulnerable customers?

a. True

Customers suffering from or experiencing mental health issues are defined as being vulnerable due to the symptoms that mental health issues can cause. These can include (but are not limited to), depression, stress, anxiety, confusion, suicidal thoughts or tenancies, self-harming, inability to understand or comprehend and apathy.

4) The Vulnerable Customer ethos goes hand in hand with?

c. Treating Customers Fairly

TCF is about organisations being clear, transparent and open in their approach and dealings with customers and as such how vulnerable customers are identified and treated is a part of TCF. If a company embraces the principles and ethos of treating customers fairly, it also by the very nature of its policies and processes should embrace vulnerable customers and have measures, support and training in place.

5) Name 3 categories of vulnerable customers: –

• Elderly
• Mental Health Issues
• Physical Illness
• Impairment (deaf/blind)
• Low Income
• In debt
• Unemployed
• On benefits
• Bereaved
• Language Barriers
• Learning Difficulties

MARKER NOTE: Award the marks for the answer based on the respondents understanding of the vulnerable categories – i.e. they may have explained an individual vulnerability as oppose to using the bullet points above.

There are many situations, circumstances and disabilities that can make a customer vulnerable and what makes one person vulnerable does not necessarily apply to the next. It is important that staff understand the vast number of situations that can cause vulnerability so that they can look out for them during contact and communication.

When a customer is defined as being in a vulnerable category, it does not instantly prevent the service or product from being put forward, however it does mean that additional probing is required assess and ensure that what staff are offering is applicable, appropriate and needed by the customer.

“Vulnerability can come in a range of guises, and can be temporary, sporadic or permanent in nature. It is a fluid state that needs a flexible, tailored response from firms. Many people in vulnerable situations would not diagnose themselves as ‘vulnerable’.”

6) You should always terminate a call once you realise that a customer is vulnerable?

b. False

When a customer is defined as being in a vulnerable category, it does not instantly prevent the service or product from being put forward, however it does mean that additional probing is required. Assess and ensure that what staff are offering is applicable, appropriate and needed by the customer.

Some vulnerabilities such as being elderly or having suffered a bereavement may just mean spending more time with the customer and explaining in more detail or slower what you have discussed and are offering/suggesting.

7) A customer mentions to you that her Husband recently passed away. Do you: –

c. Offer your sympathy and proceed at a slower pace, ensuring the customer understands what you are discussing and that they can make decisions at this time.

A customer who is in a state of bereavement at having just lost a close family member may not take on information in the same way they normally would. It would be common for their mind to wander and to not hear or miss things that you are saying. However, if you are offering them (for example) a contents insurance policy or are a debt collection agency collecting an outstanding invoice, the customer may still need you to proceed ahead in their best interests.

Sending information and/or agreements out in writing after a conversation with a vulnerable customer is one of the most important ways of ensuring you are paying due regard to their needs and interests.

8) List 2 things that you could do to help a vulnerable customer: –

• Be Patient – take your time with the customer and do not rush
• Be Flexible – some vulnerable situations can be helped or overcome by being flexible and altering both your approach and service
• Be Empathetic – put yourself in the customers’ shoes and show them that you have listened and understood what they have said
• Reiterate – always repeat information and reiterate outcomes or consequences prior to getting agreement
• Explain – avoid jargon and use layman’s terms when explaining complex or technical information

MARKER NOTE: There are many other ways to help and identify vulnerable customers and many are specific to your business or industry, so it is important for the tutor to look at the answers provided and decide on marking them.

9) I don’t speak to customers on the phone or face to face so learning about vulnerable customers is not applicable to me or my job role.

b. False

Dealing with vulnerable customers and learning about what makes someone vulnerable and how to deal with arising situations should fall to every person within an organisation, from those at the top and all the way down.

10) The customer you have been speaking to has agreed to the product/service that you are offering but has displayed signs of being hard of hearing throughout the conversation.

What could you do to ensure that their vulnerability has been noted and addressed?

a. Send everything you have discussed out in writing to the customer and sign them up after they have had time to read through everything.

Recapping and reiterating everything in writing is a must with all vulnerable customers. This then gives them the opportunity to have a friend, relative, carer or advisor help them, or provides extra time to digest the information and make an informed decision.

This is the end of the test 1 answer paper. Where you have identified any gaps or misunderstandings in an assessment, you should use the additional answers provided to teach and support the respondent. You should also scan/save a copy of the completed quiz and marking sheet and complete any assessment/evaluations forms that you use for training and development and record these in the employees training file.

5 Vulnerable Customers Assessment Answer Sheet 2

Below are the answers to the second assessment test paper; the correct answer is provided in red underneath each assessment question. We have then provided detailed information about the question and answer which should be relayed to the assessment taker where any gaps have been identified. Use the mark guidance for scoring each answer.

1) List 2 FREE debt counselling providers whom a vulnerable customer can be referred to: –

• Citizens Advice Bureau – adviceguide.co.uk
• National Debtline – 0808 808 4000 or nationaldebtline.co.uk
• StepChange (formerly CCCS) – 0800 138 1111 or cccs.co.uk
• Money Advice UK – 0300 500 5000 or moneyadviceservice.co.uk

Where the customer is showing signs of, or experiencing financial hardship, you should always ensure that you provide and signpost access to free and impartial help for the customer and include the below contacts in our communication with the customer.

2) Which of the below could be a sign of a customer’s vulnerability?

a. Confusion and misunderstandings
c. Asking you to repeat most things that you have said

If a customer displays signs of being confused when you are talking, or they appear not to understand what you have discussed or are offering, there is a good chance that they are in a vulnerable state.

The reason for the vulnerability could be put down too many different issues such as a recent bereavement, mental health issues, learning difficulties or language barriers. However, the actual reason is not as important as the fact that you have identified symptoms of a possible vulnerability and should proceed with care and caution.

3) List 1 verbal and 1 written indictor that a customer may be vulnerable?

VERBAL INDICATORS                                     WRITTEN INDICATORS

Indecisiveness                                                             Many spelling errors

Repeating                                                                    Confusion in content

Misunderstanding                                                       Language barriers

Confusion                                                                    Miscommunication

Not answering

Asking non-relevant questions

Long pauses

 

MARKER NOTE: Award the marks for the answer based on the respondents understanding of the vulnerable indicators and not just those listed above.

When dealing with a customer, there are often tell-tale signs that they may be vulnerable. It is important for staff to listen and know what to look out for as not all vulnerable customers see themselves as such and so may not officially disclose the information or situation.

Verbal Indicators – If you are dealing with customers on the phone or face to face, there are often signs of vulnerability that can be detected. It can be very easy for call centre staff who follow scripts and are used to a set call regime to miss these indicators and plough on regardless.

Written Indicators – when corresponding with customers by letter or email, signs that they are vulnerable are not as clear as verbal ones. For example, talking to someone on the phone, indecisiveness and confusion are clear but in writing may not be present as the customer has had more time on their own to write the information and think it through. Language barriers can

still be present even in writing form the grammar, spelling or general format of the text. Also, look out for the customer asking a lot of questions or showing misunderstanding in the way they describe the business or service you have offered.

4) Who/What are the Money Advice Liaison Group?

MARKER NOTE: Award the marks for the answer based on the respondents understanding of who MALG are and what they do. It does not have to mirror the description below.

The Money Advice Liaison Group (MALG) is a UK non-profit organisation that were formed as a non-policy making, free to client unincorporated association in 1987. It was formed by a small and select group of people and firms taken from backgrounds and sectors in debt advice and lending.

MALG is grown extensively since its inception and is now seen as a leading authority on debt advice and mental health guidance for vulnerable people and the firms who deal with them. Membership includes a wide range of voluntary agencies, private organisations and public-sector bodies, all of whom have an interest in personal debt. MALG holds a prestigious annual conference and exhibition and attendance is recommended to creditors, debt collection agencies, debt advisers, regulators and everyone working within the consumer credit and debt industry.

5) List 3 mediums that can be used to communicate with a customer to reduce any misunderstandings?

Post                 Braille              WebChat                     Website                       Email

SMS                 Phone             Face-to-Face               Audio                          TypeTalk

Video  

MARKER NOTE: Award the marks for the answers based on the respondents understanding of the question, including any mediums or formats that your firm uses to communicate effectively.

6) You cannot sell a vulnerable person a financial product or service/or ask them to donate to a charity?

b. False

Just because a customer has been identified as vulnerable, does not mean that they do not want or need the products/services that a firm offers. Elderly people still need insurances policies, those with financial difficulties may still need to deal with debt collection agencies or those suffering from bereavement or depression may still want to donate to their favourite charity.

The main thing to remember is that those with vulnerabilities need to be afforded more time, patience and understanding when setting up agreements and/or arrangements and that where any financial difficulties are concerned; checking that payments can be afforded through assessment is essential.

7) What does Signposting mean?

With regards to debt, charities or finances and vulnerabilities – signposting is where a firm provides easy to see and understand access to and information about non-profit third parties who can offer free guidance for those who are vulnerable and/or are experiencing financial difficulties.

8) Why is summarising important?

MARKER NOTE: Award the marks for the answer based on the respondents understanding of why summarising is important. It does not have to mirror the description below.

Summarising what has been discussed in a call is an essential and important business practice in all instances, however, it is mandatory when dealing with vulnerable customers. In credit and financial sectors, customers are setting up repayment plans, taking out loans, agreeing to long-term policies, signing up to monthly charity donations and so forth, all of which necessitate a thorough understanding of the product/service and the consequences of defaults.

At the end of a phone call, going over the main aspects of the agreement via bullet-point is a great idea and helps the customers to re-listen to what has been discussed and agreed. Summaries should also be done via letter where the initial communication was via the telephone. This gives the customer the chance to re-read the points discussed and to gain a better understanding through assistance if needed.

9) If you identify someone as being vulnerable, you can deal with a third-party on their behalf without asking permission?

b. False

Authorisation to deal with any third-party, including family members and debt management agencies, must always be obtained from the customer prior to discussing or disclosing any personal information. Most firms have processes in place to gain a written letter of authorisation as extra security that permission has been given to discuss and divulge information to a selected third-party.

Where a person is identified as vulnerable, it can be a good idea to have a person speak on their behalf, however this is at the request and discretion of the customer in all cases.

10) What is a Debt & Mental Health Evidence Form?

b. A form used by healthcare professionals, debt advisers and creditors to more effectively evaluate debtor circumstances and arrive at informed decisions

The latest version of the Debt & Mental Health Evidence Form (DMHEF) was launched in November 2012 and forms an integral part of the Guidelines offered by MALG. The form was developed by MALG and Chris Fitch at the Royal College of Psychiatrists and assists healthcare professionals, debt advisers and creditors to more effectively evaluate debtor circumstances, enabling them to arrive at informed decisions.

6 Test Marking Sheets