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Vulnerable Customers Policy

We aim to make financial advice accessible to everyone regardless of their financial and personal circumstances.


1        Introduction

2        Our policy

3        Who may be vulnerable?

4        How to identify a “vulnerable client”

4.1     Additional support indicators

5        When may a client need additional support?

6        Examples and relevant support

6.1     Elderly clients

6.2     Students and very young clients

6.3     Recently bereaved clients or those diagnosed with serious illness

6.4     Clients dealing with major life changes

6.5     Clients with conditions or disabilities

6.6     Clients whose first language is not English

7        Methods of support

8        Documentation

8.1     Fact find and suitability report

8.2     Other documentation




1      Introduction


The FCA aim to make financial advice accessible to everyone regardless of their financial and personal circumstances. The FCA defines a vulnerable client as:


‘Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’

The FCA has published its analysis and guidance on dealing with vulnerable clients. Occasional Paper No 8 – Consumer Vulnerability’ states:


“Much consumer protection legislation is underpinned by the notion of the average or typical consumer, and what that typical consumer might expect, understands or how they might behave. However, consumers in vulnerable circumstances may be significantly less able to represent their own interests, and more likely to suffer harm than the average consumer. Regulators and firms need to ensure these consumers are adequately protected.”


We believe that as a business that we should have a dedicated policy in place to ensure that such clients are afforded appropriate protection by the use of training, adequate policies and other control/oversight mechanism both in the identification and methods of dealing with this type of individual.

This is our policy which describes how to identify vulnerable client types and our expected methods for dealing with such.

2      Our policy


It is our policy to conduct all business in an honest and ethical manner. It is important to have in place appropriate processes, training and policies to protect the client, this policy will cover the considerations to be made when dealing with each category of vulnerable client.

All staff have a responsibility to identify when a client is vulnerable, and it is the firm’s responsibility and duty to manage the risk of incorrectly treating a vulnerable client, through the development and maintenance of effective systems and controls.


3      Who may be vulnerable?


Anyone may be vulnerable at different stages in life depending on their circumstances. Clients may require varying levels of support through these different life stages. There is no exhaustive list of clients who are vulnerable and we need to be observant for indications of where our clients may need support.


Examples of clients who may potentially be vulnerable are:


  • The elderly, including those suffering from dementia

  • The very young, and students

  • The recently bereaved

  • Clients who have been diagnosed with serious and/or life-threatening conditions

  • Clients dealing with life changes or stressful situations (e.g. divorce, moving home, job changes, financial pressures)

  • Clients with conditions or disabilities

  • Clients who do not have a full understanding of the English language


Occasional Paper No 8 – Consumer Vulnerability’ states:


"Vulnerability affects us all


Vulnerability can affect any of us, at any time. We, or our family and friends, can all face times of stress and difficulty, when our abilities to cope may be compromised. For example, we may experience a change in circumstances such as job loss or bereavement, or onset of a serious illness. In some cases these difficulties may be short lived, but for many they may be longer term or permanent. Large numbers of people have longstanding physical or mental conditions that can make interacting with financial firms challenging.”


4    How to identify a “vulnerable client”


It may be quickly evident that some clients require additional support (for example, a client with a guide dog, or a client using a wheelchair). For other clients, it is important to be conscious of the indicators that may suggest they would benefit from additional support.

This applies to advisers and all other colleagues who may deal with clients. For example, a client may indicate that they cannot use the stairs to reach our office; a colleague processing financial information may identify that a client has cancelled several policies. These could be indicators of physical disabilities or financial pressures respectively.

4.1     Additional support indicators


We will ensure we consider common indicators of circumstances where additional support may be required. No list can be exhaustive, and examples could include:

  • Observing changes in circumstances for an existing client

  • Verbal indications – e.g. “can’t come into the office”; “are there any stairs”

  • Communication difficulties – e.g. clients who are uncomfortable with email or computer, or asking for help reading documents

  • Changes in the client paying premiums, payments stopping suddenly, late or missed payments

  • Physical indications – e.g. shortness of breath or signs of agitation, or mention of medication

  • Client understanding – e.g. client asking for repetition (a sign that the client is not retaining information), other signs that the consumer has not understood, or signs of confusion.


5    When may a client need additional support?

We may identify that the client needs additional support at any time during the relationship with the client. It is not solely during the advice process.  For example:

  • The first contact – prior to any advice

  • Throughout the advice process during discussions and meetings

  • Post Sale – for example, if a policy has lapsed or premiums have been missed

  • Claims – a stressful time when the client may need support

  • Dealing with Correspondence – for example, if a client has difficulty understanding details


6    Examples and relevant support


6.1     Elderly clients

Why may a client be vulnerable?

As clients reach key stages in life and their circumstances change they may need additional support to understand the implications and the advice given.

In particular, when clients reach retirement age additional support is commonly required. We need to pay particular attention to the client’s individual circumstances as retirement ages vary.  State retirement age (SRA) has undergone a review for a number of years, firstly to equalise the female/male SRA to 65, and then to further raise the SRA.

It is also possible elderly clients may require support to deal with conditions or illnesses which become more common with age. For example, clients may require assistance due to poor hearing or eyesight. Clients who may be suffering from the early stages of dementia could have difficulty recalling facts or understanding advice.

What support may be required?

For clients with hearing, sight or any mental impairment, we should ask for an independent person to be present at the meetings. This could be a close relative or a responsible person (for example, a nursing home representative).

For clients dealing with changes to circumstances (e.g. retirement), we may need to allocate additional time to appointments to ensure all circumstances are fully discussed and the client has sufficient time to carefully consider our advice, and decide if any of the advice should be deferred until circumstances are more settled.

There may be particular times of day when the person's understanding is better, often due to their medical conditions and medication. The person may feel at ease in a particular place or maybe anxious if there is too much noise.

Decisions and conversations may sometimes need to be put off until a later time when the person is more able to make the decision.


Effective communications should always be broken down into bite-sized chunks of information.

Dysphasia, for example, is a condition common in stroke victims and older consumers where the person knows perfectly well what they want to say but cannot get the words out. 

Also, some health conditions may make it harder for a person to respond to questions even though they understand them. It is important to give the person enough time to answer a question and avoid making them feel hurried.

6.2     Students and very young clients

Why may a client be vulnerable?

Generally speaking, clients who have just started earning and students have a modest income and little (if any) experience in organising their finances. For example, students may be dealing with student loans and living expenses; clients in their first jobs are dealing with new levels of income, emergency tax codes and often paying their first rent; funding their first home and maybe considering things such as car finance.

Although younger clients rarely have long-term protection needs they will commonly need advice for such things as contents cover – and often have little knowledge or experience with insurances.

What support may be required?

For clients with limited or no experience of dealing with insurance, we may ask for an independent person to be present at the meetings – for example, a parent of the client.

6.3     Recently bereaved clients or those diagnosed with serious illness

Why may a client be vulnerable?

Clients who have been recently bereaved or diagnosed with serious/life-threatening illnesses are often not in a position to consider long term planning objectively. The client may be dealing with their own grief or the implications of a diagnosis. Understandably, clients often find it difficult to focus on technical information, facts/figures or to make decisions for their future. 


What support may be required?

Often the support of a third party is essential. This helps support the client and enables us to double-check that the client is able to understand and deal with information.

Scheduling of advice and appointments should be carefully undertaken – and it is advisable to consider deferring any decision which does not need immediate action.

6.4     Client dealing with major life changes

Why may a client be vulnerable?

Clients may suffer from stress because of the pressures of major life events and find it difficult to deal with the complexities of financial advice. Everyone deals with situations differently and we should consider what support the client may need if they are dealing with stress. For example:

  • Divorce – We may be advising a client on the purchase of a new home, or transfers of equity for existing mortgages/homes moving home, transfer of investment assets or pension decisions

  • Job changes – clients may be taking advice regarding replacing protection benefits which were provided by previous employers; perhaps moving pensions as a result of a new employer. There may be additional pressures on a client if job changes are as a result of redundancy.

  • Moving home – moving home can be a very stressful experience. At this time of stress to understand a detailed mortgage illustration, all of the relevant insurances which may be required, and deal with the costs involved, can be daunting.

  • Financial pressures – a client may be in arrears with a mortgage/rent, or lapse an insurance policy due to financial pressures.


What support may be required?

Consider how much information can be comfortably covered during an appointment. Rather than one long meeting lasting a few hours, would it be in the interests of the client to have a series of shorter meetings?


  • Throughout the discussions, we will regularly re-confirm the client’s understanding.

  • Consider whether the client may be more at ease in their home environment rather than an office.

6.5     Clients with conditions or disabilities


Why may a client be vulnerable?


We will ensure that we are aware of the requirements under the Disability Discrimination Act. This obligates giving equal access to services irrespective of an individual’s disability.


Clients with physical disabilities (for example, restricted mobility) may have difficulty travelling to our offices, accessing offices that have access via stairs, or may require disabled parking facilities.


Clients with conditions such as dyslexia or dyscalculia may have particular difficulty in dealing with the considerable written and numerical information that is involved in any advice process.


6.5.1     Not all disabilities are visible


Some disabilities are more easily identified and we will be able to quickly determine if the client requires additional support – for example, blind or deaf clients. In these circumstances, communication may be restricted, and the methods of presentation and explanation of advice will need to be reconsidered.


Where disabilities are not evident or visible it can sometimes be more difficult to identify where the client may need additional support – for example, if a client has learning difficulties. We will our judgement on a case by case basis when considering if clients would benefit from additional support.

What support may be required?


The support required will, of course, depend on the individual client’s requirements. Considerations for clients with conditions or disabilities include:

  • Providing relevant documents in Braille.

  • A qualified sign-language interpreter for clients with impaired hearing.

  • Arrange for a third party, such as a friend or relative of the client, to be present. This can help with explanations, interpretations and to gain confirmation of understanding. It can also be of great reassurance to both the client and their chosen third party that we are ensuring the client is receiving the full benefit of our advice, and they are not being excluded because of their disability. Any third party may be asked to review the fact find, and documents used in the presentation, with the client. The third-party should confirm (preferably in writing) that All appropriate information has been conveyed to the client, and this has been fully understood by them


6.6     Clients whose first language is not English


Why may a client be vulnerable?


We may advise clients whose first language is not English. We will make a judgement on whether the client’s command of English is sufficient to understand the advice we will provide, or whether additional support is needed.

Where we decide that the client’s English is sufficient to understand the advice then will proceed as normal.

Where we are unsure about a client’s ability to understand the advice process in English then further action will be needed. Without additional support, we would not be able to confirm that we have accurate ‘know your client’ information or demonstrate the accuracy of the advice. The client may not be sufficiently informed and may then make decisions based on misunderstanding or misinterpretation. This scenario would not be treating the client fairly.

What support may be required?

6.6.1     Where we are not fluent in the client’s own language


Where we are not able to communicate fully in the client’s first language we will consider whether we can arrange for an individual fluent in both languages to act as an interpreter. This could either be a professional interpreter, a friend or a relative of the client.

In these circumstances, the interpreter should confirm (preferably in writing) that all appropriate information has been conveyed to the client, and this has been fully understood by them.


Where we do not feel confident in a client’s ability to understand the advice after the above options have been explored, it may be necessary for us to refer the client to another firm that is better equipped to cater for their specific needs. This would help to ensure that the client receives a good outcome.


6.6.2     Correspondence


Written correspondence with the client (for example, the suitability report) will be in English. It is important to encourage all clients to ask any questions they have or seek clarification on anything they do not understand.

Where our client has English as a second language, and we are unsure that the client’s command of English is sufficient to understand the advice, the recommendation to seek clarification will be confirmed in the suitability report. This also should offer a suggestion they obtain a translation from a third-party.

7       Methods of support


The support required will of course depend on the individual client and their circumstances. Solutions may include:

  • Arranging for a third party to be present at the meetings (e.g. family member, companion).

  • Obtaining relevant documents in Braille for clients with vision impairment

  • Organising for a qualified ‘signer’ for clients with impaired hearing.

  • Allocating additional time for appointments; spreading the advice process over several shorter appointments

  • Deferring a review of your client’s circumstances until they have had time to come to terms with their situation.

  • Changing the venue of meetings to assist clients who have difficulty with mobility.

  • Post sale contact to ensure the client understands the suitability report and other post-sale documentation and to offer further explanations or support as required.


8       Documentation


8.1     Fact find and suitability report


We will ensure that the fact-finding is thorough enough to be able to identify any vulnerability the client(s) may have. We will document within the fact find and suitability report any vulnerabilities identified and how these have overcome these(for example, if a third party was present or if we have provided information in Braille etc)


We will also confirm any actions we have taken in a suitability report.

What support may be required?

We will follow up any written communications (such as letters) with a phone call to check if it has been received and read by the client, to ask if the content was clear enough and whether there are any questions. Writing a detailed letter to an older person or vulnerable consumer is of little benefit if they do not understand it.

We will Improve the clarity of written communications by:

•    Writing in shorter sentences
•    Avoiding jargon
•    Using short blocks of text, headings, short paragraphs, bullet points and tables.
•    Putting the main points at the start of the letter and other detail later or in a separate appendix.
•    Using larger font, and checking the recipient’s needs if they have any sensory impairments.


Offer choice of how the information will be given whilst remembering that many older clients do not use websites or email or may not have anyone to provide support for them


Consider whether someone else may be able to offer support (such as a close family member, a carer, interpreter, or a speech and language therapist) - but be mindful of potential conflicts of interest.


We will not


  • Use unnecessary detail. By providing communications in clear, jargon-free language, you can help consumers understand them.

  • Forget to address any known or particular difficulties in a face-to-face meeting, including English not being a first language, using sign language or visual aids.

  • Alienate the vulnerable clients by just talking to their family member, support worker/ carer - where possible we should maintain eye contact and ensure that all questions are addressed to the older person instead.

8.2     Other documentation


In addition, where a client has executed a Power of Attorney, a copy of this will be obtained and retained on the client’s file.

It is important to check that the power of attorney deed is valid, and does not contain any restrictions that would prevent us from advising the attorney. It’s also important to ensure that nothing has happened which would have the effect of revoking the arrangement, such as mental incapacity of the donor under a general power of attorney.

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