Practical ways advisers can deal with vulnerable customers

Describe the FCA's stance on vulnerability
Explain the acronyms associated with helping vulnerable clients
Describe when to outsource to a specialist

CPD

Approx.30min

If you have identified a vulnerability, the next step is to consider how it is recorded and what, if any, changes you make to your sales or service processes and outcome.

When dealing with the client there are a number of academic theories that are widely used when handling certain types of vulnerabilities. This article is not designed to provide you with the skills to apply these in practice, but simply to make you aware of some of the approaches that you can take.

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The use of these theories is often recognised by way of their acronyms and include:

Bruce.
Idea.
Texas.

Each of these theories adopt a different type of questioning to understand, interact and support people in areas of health and mental health.

Bruce – When your client has mental capacity limitation

Behaviours: Consider the things a customer says or does. These may be triggers that suggest they are struggling with decision making.
Remembering: 'Would it be helpful if I went over that again?', 'Would it be helpful if I put that in writing?', 'Is there someone that usually helps you with your finances?'
Understanding: 'Do you want to tell me what you have understood so far and I can fill in gaps?', 'Would it help if I explained that again?'
Communicating: 'Is there another way you’d like us to communicate with you?', 'Is there another time when it would be better to have this conversation?', 'Take your time'.
Evaluate (or weigh up options): 'Would it be helpful to go through each option again?', 'Do you have someone you normally talk these things through with?'

Idea – When talking to a customer about their situation or health condition

Impact: 'What are you finding hard?', 'What has been the impact on your day-to-day living?'
Duration: 'When did this first start to happen?', 'How long have you been experiencing this?'
Experience: 'Is this happening often?, 'Have you experienced this before?', 'Could it happen again?'
Assistance: 'Are you receiving any support/assistance/medication?', 'Have you asked about whether you’re entitled to more support/assistance/benefits?'

Texas – To gain consent to record sensitive information shared by your client

Thank them: 'Thank you for sharing', 'I appreciate you telling me what is going on for you', 'I appreciate you sharing how you are feeling'.
Explain how the information will be used: 'I can make a note on our records', 'This will mean you will not need to keep repeating yourself', 'It will help us support you better', 'We can see what we can do to help', 'This information will only be shared within our organisation'.
Gain eXplicit consent: 'Are you happy for me to make a note of what you have shared today?'
Ask: 'Is there anything you would like us to do which will help?', 'Are you getting any help from anywhere – for example family?'

You can also use Idea for additional help on asking questions.

Additionally, it is helpful to signpost: 'Some of our customers have found it helpful to speak to...', 'Do you have a list of external experts we can signpost to?', 'Leave it with me and I’ll see what more we can do to support you'.

The regulator has reinforced the importance of embedding the fair treatment of vulnerable customers within a business numerous times, and also that all relevant staff should understand how their role affects the fair treatment of vulnerable customers.

The regulator’s expectations for relevant staff within a business are:

Ensuring that frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability.
Offering practical and emotional support to frontline staff dealing with vulnerable customers.

I also believe that requiring staff to undertake training around the fair treatment of vulnerable customers is an excellent way for senior managers at a business to demonstrate that they have taken reasonable steps to embed it into their business's policies and culture.

Dealing with vulnerable customers can be a complex area and some clients experiencing certain types of vulnerability may need specialist support, either in the long or short term.

In my role at SimplyBiz, I have been working closely with our partners to provide the businesses that we serve with a wide range of solutions to support them in their work with vulnerable customers.

We have details of, and resources and support material from, third-party organisations that provide expert advice and guidance to assist the businesses that use our services.

I am conscious that everyone reading this article does not use the services of SimplyBiz, and for those readers I would recommend the Financial Vulnerability Taskforce as a useful source of information.

The FVT is an independent professional body covering the personal finance, insurance and wider financial services sector. Its purpose is to promote greater understanding, encourage appropriate behaviours and establish good practice in respect of consumer vulnerability.

FVT’s website has a wealth of information, and a resource library where you can find useful material and support related to vulnerability.

We know that the fair treatment of vulnerable customers is a key area of focus for the regulator, and it has produced a lot of guidance for businesses, but we also know that the FCA has not – and will not – make specific rules to address each area of vulnerability.

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