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:
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.
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:
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:
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.
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:
As a firm, we commit to considering the vulnerability of our clients in all of our dealings with them.
Information to be aware of:
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.
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’.
The use of words such as ‘illness’, ‘depression’, speaking with agitation, high pitch, irritated tone etc.
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.
The firm is currently considering a reward scheme for staff which clearly demonstrate the ability to manage a vulnerable customer situation.
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.
Solutions Scotland is a trading style of Milton & Stirling Ltd, Company Number SC587851 – Solutions Scotland, 78a Stanley Street, Glasgow, G41 1JH. DPA number ZA431921
Milton & Stirling Ltd are an Appointed Representative of MichaelAlan Ltd who are authorised & regulated by the Financial Conduct Authority, FRN 690939.
As part of our free service, we’ll review your financial situation, explain the available options and recommend a debt solution which is suitable for you. The risks of all suitable solutions will be explained clearly and if you decide to go ahead with a debt solution we will refer you to one of our trusted providers who specialise in the management of that debt solution. We’ll be paid for introducing you or for the preparatory work we do, depending on your debt solution fees may be payable if ongoing services are provided. Read about fees and key information in our terms & conditions. To find out more about managing your money and getting free debt advice, visit Money Advice Service , an independent service set up to help people manage their money.