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Vulnerable Customers
Other than in relation to debt advice under CONC 8.2 and the Mental Guidance requirements in CONC 2.10, the FCA only provides limited guidance on dealing with vulnerable customers. However, the company is committed to identifying, assessing and managing vulnerable customers in accordance with our own defined objectives and procedures and we aim to treat all customers who we define as being vulnerable, in a fair, clear and respectful manner.
We have implemented several identification and assessment tools and a vulnerable customer’s policy to ensure that staff are aware of and knowledgeable about vulnerable customers, including how to handle certain situations.
We have also included external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).
16.5.1 Approach to Vulnerable Customers
The company ensures that all staff are made aware of what a vulnerable customer is, how they can, and should deal with them and what measures and tools they can use to ensure that vulnerable customers and their situations are handled appropriately and effectively.
The company’s two main definitions are used to define what a vulnerable customer is to us as a firm: –
- 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 added financial stresses. Staff and your organisation have a duty of care to ensure that you do not cause undue stress to customers who may be in vulnerable situations. Many customers do not know that they are vulnerable and so do not think to disclose this information during contact with you.
We ensure that all staff are aware that 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.
16.5.2 Identifying Vulnerable Customers
The company provides our staff with reference guides, scripts and reminders to help them identify a vulnerable customer.
Verbal Indicators
If staff are dealing with customers on the phone or face to face, there are often signs such as the customer showing difficulty in hearing what is being said, displaying a lack of understanding, language barriers, long pauses and delays in answering, mentioning vulnerability issues and showing signs of indecisiveness.
Written Indicators
When corresponding with customers by letter or email, we ensure that staff are made aware of signs that they are vulnerable, as these are often not as clear as those in verbal or face to face situations. Language barriers can still be present even in writing form the grammar, spelling or general format of the text. We also advise staff to look out for the customer asking a lot of questions or showing misunderstanding in the way they describe the business or service that has previously been offered.
16.5.3 Debt & Mental Health – MALG
Staff who may come into contact with 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.
16.5.4 Debt & Mental Health Evidence Form (DMHEF)
If you are a DMA or DMC and you require evidence from a customer as to their declared or suggested mental health being an issue as to repayments of debts, please refer to the Debt and Mental Health Evidence Form which is available from http://www.malg.org.uk/dmhdocuments/DMHEF V3 1.12.12.pdf