The FCA has recently updated Occasional Paper No. 8, within which it explains a vulnerable consumer as such: “… 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 focus on this area seems to be continually increasing. So what should firms do to ensure it is treating all customers fairly?
1. Audit your current procedures. Look at your processes, such as how you communicate in writing, product/suitability report wording, how you deal with clients face to face and on the telephone. If you knew they were vulnerable, what would you do differently? Can you simplify wording in documents while remaining compliant?
Most importantly, though: how can you tell if a client is vulnerable? Remember clients can be temporarily vulnerable, too. How would you assess this? It might be through things they say to you, such as asking you to repeat yourself.
2. Develop a written policy and make sure all your staff are clear what to look for. Everyone in your firm needs to understand how to spot a vulnerable client and how to alter their behaviour accordingly. For instance, passing a vulnerable client from person to person over the phone would only serve to confuse them.
3. Regularly evaluate and monitor how the procedures are working. How do you know you are getting it right? Have staff had any problems or difficulties in spotting vulnerable clients?
Jacqueline Lockie is deputy head of financial planning at the Chartered Institute for Securities & Investment