In 2021 the FCA provided its final guidance on the fair treatment of vulnerable customers (FG21/1) which focused on six key actions that firms should take to ensure they’re providing the right support. These included customer service, product and service design, monitoring and evaluation, communications, skills and capability of staff, as well as understanding customer needs.
Despite the in-depth nature of the final guidance, vulnerability also appears in the Final non-handbook guidance on the consumer duty (FG22/5) a further 110 times, further confirming that the regulator has high expectations from firms to do the right thing when their customers experience vulnerabilities. This becomes even more important when firms are working across multiple providers and platforms.
However, there are still some pitfalls that can get in the way of advisers and their chosen providers to provide the best support. So in this article I’m going to share some top tips for bridging the gap and getting the most out of your platform providers.
1. Make sure you obtain appropriate consent
Sharing data about customer vulnerability can be tricky as often we’re talking about special category data under GDPR. This means that we need the customer’s explicit consent before we can process their data and provide the right support. Having a joint template or pro forma that you can complete with your customer and have them sign will allow you to evidence that you have obtained consent and let you share this evidence and consent with your provider. Make sure that the client is fully aware of where the information will be shared, and ensure they have explicitly agreed for you to share it.
2. Shout about your support
The FG21/1 final guidance on the fair treatment of vulnerable clients (4.34) states that “Firms should be proactive in offering support. They should enable consumers to tell them about any additional needs they have…”
You can shout do this in many ways: from having a dedicated space on your website to including a paragraph in your letters and emails that tells people about what you can offer. Or even mentioning this in calls and face-to-face meetings.
We recently launched our new Nucleus Cares page online to help signpost our customers to the right internal and external support to help suit their needs.
3. Be flexible
Flexible customer journeys and service can really improve the experience for those living with vulnerabilities. “Unresponsive or inflexible customer service can exacerbate difficulties in accessing services. Difficulties with access can lead to disengagement, exclusion, mistrust or even risk of scams as customers may instead rely on informal access methods.” (FG21/1 2.24B).
Some clients, due to age, poor vision or capability may struggle with online processes and those with limited or no internet access may be disadvantaged by online only services.
Consider including ‘positive friction’ in your customer journeys to give customers time and space to think about their financial objectives and ask questions if they get stuck. Positive friction is a term used to describe experiences where the consumer has been slowed down on their buying journey, but find it to be a positive experience.
4. Empower and engage your people
One of the fundamentals of providing great support to vulnerable clients is the ability for them to tell you once about their circumstance. This means having well trained and empowered people on hand to identify, record and react to any disclosures of vulnerability on the spot.
At Nucleus we have several support solutions that are ‘whitelisted’ to allow for speedy responses to customer vulnerability. We keep these in our Vulnerable Customer Guidebook, which allows our customer facing team to quickly look up a specific condition, life event or circumstance and signpost to the appropriate support measures we can provide.
Having well trained and engaged people supports 3 of the 6 actions outlined in FG21/1 by helping understand customer needs, increased skills and capability of staff and improved customer service.
5. Understand the impact of neurodiversity and mental health on communications with your clients
An important part of being flexible in your communications is the ability to meet specific needs around access for customers with poor vision, neurodiversity or poor mental health through alternative literature options (Large print, Braille, Text to speech etc). This will also help you meet reasonable adjustment requirements outlined by the equality act 2010.
Customers with poor mental health and neurodivergences such as ADHD, Autism or severe Dyslexia or Dyscalculia will struggle more than other customers to communicate in writing and are less likely to open post than others. This sounds very generic, but I recently spoke with a financial services customer living with ADHD and she concurred: “Never send me a letter because I won’t open a letter! I’ll open a text because it’s on my phone and I understand my phone, don’t send me an email either… that would really help me!”
6. Tap into existing support
Historically many firms would only be comfortable sharing data or speaking with a person who holds power of attorney for our customers. However the new Consumer Duty rules expand this remit: “Where a person is authorised by a customer, or by law, to assist in the conduct of the customer’s affairs (such as where power of attorney applies), firms should provide the same level of support to that person as they would have provided to the customer.”
A practical example of this would be to consider a customer with low digital capability trying to perform an online task. No matter how well trained your people are to support a customer with self-service online, limited capability can make this virtually impossible. However, by tapping into the customer’s existing support network, we can often explain the required actions to a representative who understands the customer’s situation and can talk to the customer themselves.
Bear in mind that relevant ID and Anti Money Laundering checks will need to be carried out on this representative and additional safeguarding measures.
7. Monitor, evidence and evaluate your outcomes
The process of measuring good outcomes often starts with mapping your client journeys and overlaying specific pain points or moments of friction experienced by those with vulnerabilities.
Monitoring and evaluating outcomes for vulnerable clients will touch every element of your business, from including considerations about vulnerability into your product and service review cycles to keeping an active track of your vulnerable customer population.
Because vulnerability can be permanent, temporary, and sporadic, a good test of whether your monitoring is effective is to have a constantly changing VC population, i.e, you should expect this number to go down as well as up as your clients’ circumstances improve or worsen.
And finally, a word on data: make sure you’re not just capturing data on vulnerable clients, but using this data as a tool to drive change for all clients. At Nucleus we have a dedicated vulnerable customer working group who meet regularly to discuss complex cases, review at our support catalogue, and suggest business improvements. We also use this forum to share case studies where we have provided a great outcome for a customer when they needed it the most.