Vulnerable Customers Policy

Dealing With Clients in Special Circumstances

Our firm wants to make advice accessible to everyone, regardless of their financial and personal circumstances. Large numbers of people would benefit greatly from advice but do not seek it for a variety of reasons.

For the purposes of this document, ‘special circumstances’ means:

• The elderly
• Students /young people
• The infirm
• Those in financial difficulty
• Those with hearing or vision difficulties
• Those recently bereaved
• Those who do not have a full understanding of the English language
• Those who are not of sound mind
• Those with learning difficulties

Great care will be taken to ensure that clients fully understand the information / advice provided to them. We will record any difficulties in communication that are encountered and document how the adviser overcomes these issues.

It is advisable, when having knowledge of a vulnerable client, that they are encouraged to bring a trusted friend / family member onto the phone call meeting. If this happens, a file note will be made.

Guidance on Financial Difficulties

The Firm will adhere to its own processes relating to the identification of customers who may be in financial difficulty. The following list is not exclusive, but may be an indication of financial difficulty in new / existing customers:

• Consecutively failing to meet minimum repayments in relation to a credit card or store card
• Adverse accurate entries on a credit file, which are not in dispute
• Outstanding county court judgments for non-payment of debt
• Inability to meet repayments out of disposable income or at all, for example, where there is evidence of non-payment of essential bills (such as, utility bills), the customer having to borrow further to repay existing debts, or the customer only being able to meet repayments of debts by the disposal of assets or security
• Consecutively failing to meet repayments when due
• Agreement to a debt management plan or other debt solution
• Evidence of discussions with a firm (including a not-for-profit debt advice body) with a view to entering into a debt management plan or other debt solution or to seeking debt counselling

Vulnerable Customers

Types of Vulnerable Customers

Customers can be vulnerable for a wide a variety of reasons and in a wide variety of ways. Vulnerability can be permanent, temporary or sporadic, depending on individual circumstances.

We can all become vulnerable vulnerability is often not isolated to just one reason. Examples are as follows:

• Bereavement
• Divorce / separation
• Ill health – physical or mental
• Redundancy / maternity (or paternity) leave / change in working patterns / reduction in working hours
• Stress
• Age – young (people are not savvy and sometimes do not have enough experience to question poor practice)
• Age – those in older years
• Language difficulties
• Low skills
• Low income
• Indebtedness
• Being a carer
• Mental health issues
• Physical disability (e.g. Blindness / deafness)

A sudden change in personal circumstances makes us at a higher risk of vulnerability and quite often one problem leads to another, when the overall issue of vulnerability worsens rapidly and often spirals out of control.

It’s important to remember that the perceived shame of ‘being in debt’ often means that a customer will be very reluctant to approach someone with their troubles.

Poor practice in firms

Vulnerability is not only caused by personal circumstances, but it can also be affected by the way we treat our customers. Examples of how poor practice in firms can increase customer vulnerability are as follows:

• Communication (e.g. emails, letter, phone calls) using jargon and complication terms
• Phone menus which are confusing
• Having to wait for long periods before being able to speak to a real person
• Not being given the choice of being able to speak to a person, if needed
• Being passed from one department to another and having to repeat the reason for your call each time
• Staff sticking to rules rather than taking the individual’s circumstances into account and acting accordingly
• Staff who are not trained to understand your circumstance and how to deal with them competently

As a firm, we commit to considering the vulnerability of our clients in all of our dealings with them.

Information to be aware of:

Impact on customers

If we do not respond to the needs of their vulnerable customers, then the impact can be severe. Customers may turn to other sources of action such as payday loans, or withdraw completely from their interaction with us. They also tend to take higher risks and their indebtedness may spiral out of control.

Trigger factors

Every person is different, however, when dealing with customers who are already vulnerable by way of their indebtedness, we believe that all of our customers a therefore ‘vulnerable’. Recognising additional trigger factors is key to ensuring that our clients are treated fairly.

Those customers who we identify as being subject to additional factors aside from indebtedness will also be assessed in relation to whether we class them as ‘particularly vulnerable’.

Examples of trigger factors:

The use of words such as ‘illness’, ‘depression’, speaking with agitation, high pitch, irritated tone etc.

Training of staff

Training and coaching of staff will be conducted formally and followed up with close supervision in order to determine the success of this training.

Formal classroom training will be supplemented by monitoring relating to emotional situations which most advisers find a great challenge.

Incentives for staff

The firm is currently considering a reward scheme for staff which clearly demonstrate the ability to manage a vulnerable customer situation.

Allowing sufficient time for decisions

Where the firm understands, or reasonably suspects, a customer is vulnerable, it will consider allowing the customer:

• Sufficient time in the circumstances to weigh up the information and explanations the firm has given
• Sufficient time in the circumstances to make an informed decision to proceed
• To defer a decision to proceed until a later date

Internal Controls

We will retain records in line with Data Protection and GDPR which will allow us to identify each vulnerable customer and their level of vulnerability i.e. potential vulnerability, vulnerability or particularly vulnerable. This information will be managed and monitored on an ongoing basis and management information provided to senior management on a regular basis.