ANDREW D’AURIA SOLUTIONS LIMITED has established clear and effective policies and procedures for identifying and dealing with vulnerable customers. These are first of all identified through the underwriting process.
The FCA definition of a Vulnerable Consumer is:
“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care”
Protecting vulnerable consumers is a key priority for us. We want vulnerable consumers to experience outcomes that are as good as those for other consumers. The fair treatment of vulnerable consumers is embedded into our culture, policies and processes throughout the whole consumer journey.
With vulnerable consumers, there are factors that limit their ability to make reasonable decisions and choices. So, the level of care that is appropriate for these consumers will be different from that for others.
This firm does NOT charge upfront fees for any customer it considers vulnerable where credit or mortgage related work is involved. The firm does NOT charge upfront fees for any credit broking related work.
All staff, whether customer facing or not undergo training on vulnerable clients, by passing the relevant test set on BAT.
We have identified 4 key drivers which may increase the risk of consumer vulnerability:
- Health: health conditions or illnesses that affect the ability to carry out day-to-day tasks
- Life events: major life events such as bereavement, job loss or relationship breakdown
- Resilience: low ability to withstand emotional or financial shocks
- Capability: low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy or digital skills
Characteristics of the 4 key drivers are shown in the table below. We understand that these may well overlap and become more complex.
- Health – Physical Disability, Short or Long Term illness, Hearing or visual impairment, Mental Health condition, Addiction, Low Mental Capacity
- Life events – Retirement, Bereavement, Income Shock, Relationship Breakdown, Domestic Abuse (including economic control), Caring responsibility, Other circumstances (Care/Asylum/Human trafficking/Slavery/Convictions)
- Resilience – Inadequate or erratic income, Over indebtedness, Low savings, Low emotional resilience
- Capability – Low knowledge or confidence in managing finance, Poor literacy/numeracy skills, Poor English Language, Poor digital skills, Learning Difficulties, No or low access to help and support
Generally, a person is considered to be vulnerable if it would be unreasonable to expect them to be able to deal with a problem themselves. There is no legal definition of a vulnerable person, but the National Standards for taking control of goods says this could include:
- older people
- disabled people
- the seriously ill
- the recently bereaved
- single parent families
- pregnant women
- unemployed people
- those who have obvious difficulty in understanding, speaking or reading English
- people with mental health issues
This is also likely to include people recovering from Covid.
This firm have also measures to distinguish between actually vulnerable and potentially vulnerable customers. There are three groups of people, the above two sections, plus the non-vulnerable. The firm will assess all customers into one of these three groups, when taking them on board, and this information will remain on the customer file for auditing purposes.
Where we believe that a consumer may be vulnerable, we will ask some additional questions:
- Does your health/situation make it difficult for you to repay debt?
- Does your health/situation affect your ability to deal or communicate with us? If so, how?
- Does anyone need to help you manage your finances, such as a carer or relative? If so, how?
We look for specific signs when identifying vulnerabilities in our consumers as detailed below.
- Changes in payment behaviour such as:
- payments stopping suddenly
- regular unarranged overdrafts and charges
- unusual activity on an account
- Phrases such as:
- I’m having trouble paying
- mention of breathing space/debt moratorium or contacting a debt advisor
- I can’t understand the letter you sent me
- I hate these press buttons
- Other signs:
- shortness of breath or signs of agitation
- asking for repetition (a sign that the consumer is not retaining information)
- signs that the consumer has not understood or signs of confusion
- asking for our staff to speak up or to speak more slowly
- lack of concentration for short periods of time
We will take additional steps when dealing with Vulnerable Consumers. Dependent on the situation, we will:
- Ask if the consumer wishes to have another person present at the meeting
- Speak more slowly and clearly to ensure understanding
- Check for a more convenient time to discuss the situation
- Be patient and empathise with the situation
- Provide additional time to make a decision on any services and will never pressurize any consumer into making a decision
- Never make assumptions
- Check for understanding through the entire service
- Offer alternative types of communication – phone, post, email, face to face
Under TCF outcome 6, staff must ensure that vulnerable clients are not presented with barriers preventing them from obtaining advice and transacting business. Staff should take appropriate steps to assist vulnerable clients. This may include:
- Recommend that they are accompanied at interviews
- Conduct more meetings than usual to ensure understanding is fully confirmed and demonstrate appropriate care of this type of client
- Provide documentation in bigger print or change the style of correspondence to suit the understanding of the client (Braille, larger print etc)
- Provide them with advice to seek further help.
- Refer them to a debt agency such as Citizens Advice Bureau citizensadvice.org.uk
©ADS Wales 2023
ANDREW D’AURIA SOLUTIONS LIMITED
Company number 07477648
Registered in England and Wales at office address 197 Neath Road, Landore, Swansea, SA1 2JT
Regulated by the Financial Conduct Authority under number 781215 for consumer credit broking ONLY.
