Vulnerable Customers Policy

Background:

The Financial Conduct Authority having assumed responsibility for supervision consumer credit looking at greater emphasis for the need to protect consumers. The Office of Fair Trading research paper 15 identified seven categories of vulnerable persons:

Those on low income,

The unemployed,

Those suffering from long term illness or disability,

Those with a low level of education attainment,

Members of ethnic minorities where English is not their mother tongue

Older people,

The  young.

When dealing with any Customer or potential Customer who falls into one of the categories associated with Customer vulnerability additional steps need to be taken by Staff. Staff members must takes appropriate precautions in the way that they sell and deliver services in order to ensure that the Customer is not disadvantaged in any way.

Identifying a vulnerable Customer

A vulnerable Customer is someone who, due to their personal circumstances is especially susceptible to detriment when a firm is not acting with appropriate levels of care.

Vulnerability may come in a variety of ways, it may be permanent, temporary or sporadic in nature,  many of those who are in a vulnerable situation may not define themselves as such.

When meeting a Customer face to face it may be apparent from body language and facial expressions to identify whether the prospective Customer requires additional information and guidance to enable them to make an informed decision.

When speaking with Customers over the telephone it may be more difficult to identify a Vulnerable Consumer because it is not possible to see body language and facial expressions etc.  It is critically important to listen carefully to all customers and to identify people who may be classed as a Vulnerable Consumer.  The tone of the voice may give some clues. Typical telephone characteristics may include:

Having to repeatedly explain a particular aspect of the service – either because the Customer is hard of hearing or simply does not understand what is being said.

Where the Customer provides an answer or comment which is inconsistent with the telephone discussion or which indicate they have not understood the information which has been provided.

Where the Customer admits that they do not understand or that they require the assistance of somebody else in making a decision.

When dealing with a Customer electronically (via email / SMS or other Instant messaging facility) staff neither have the benefit of observing body language etc nor the ability to pick up from the tome of the conversation any potential areas for concern.   Typical characteristics here may include :

            Incomplete or repetitive statements / questions or comments;

Having to repeatedly explain or clarify a particular aspect;

Steps to consider when engaging with a Vulnerable Consumer

It should be noted that where someone is potentially regarded as vulnerable then this does not automatically mean that our products and services are unsuitable for them.   Once we believe that we may be engaging with a Vulnerable Consumer we should immediately make a record of the same and ensure we adhere to this policy.

When engaging with a Vulnerable Consumer we should:

Provide ample opportunities for the customer to ask questions about the information we have provided.

Ask if there is anybody with them who is able to assist them.

Ask them that they have understood the information that has been provided – do this repeatedly as appropriate.

Allow them a period of reflection before completing the transaction – offer to contact on another day if appropriate.

Where a member of staff thinks that the customer does not understand the service which is being offered to them we must not proceed with the transaction.  The Customer should be informed that we will write to them with further information about the product or services they are seeking.

Where a Customer provides information which indicates that (s)he does or may have some form of Vulnerability that may impact on his/her ability to make an informed decision, this should not lead to them being automatically denied access to the service being sought.  The Firm should review its processes to ensure that the Customer is treated fairly and a positive outcome achieved for the Customer.