The knowledge: Vulnerable customers

Sandie Dunn, People Development Manager at Legal & General Investment Management – Retail (LGIM Retail), gives some advice on dealing with vulnerable customers

vulnerable customers

The Financial Conduct Authority (FCA) requires companies that sell financial products to ensure that vulnerable customers or those “susceptible to detriment” are given an “appropriate level of care and consideration” to allow them to access products and services.

Sandie Dunn ACSI outlines four tips on this, based on the FCA’s Occasional paper no.8: Consumer vulnerability.
1. Identify the Triple P

Find the people, processes and products that may be preventing customers gaining equal access to the company’s services. Look at these through the lens of different vulnerabilities and determine the barriers that may not otherwise  be apparent. For example, there may not be facilities for deaf customers to communicate in real time, so they may be forced to give security information to someone else. Or staff might not understand differences in Power of Attorney, which could result in wrongly accepting an instruction and contributing to financial fraud. Or there may be products that discontinue if the monthly investment falls below a certain amount, which could exclude customers at their most vulnerable time.

2. Involve the experts

Consult experts or any organisation relevant to your firm’s customer base. For example, LGIM Retail recently consulted experts such as Age UK and the Alzheimer’s Society, and spoke to clients at New Horizons Day Centre for people with illnesses or disabilities who require additional support. This resulted in a film being produced for staff training purposes. It highlights the various impacts of vulnerabilities, such as communication difficulties, embarrassment, or feeling rushed or confused by the volume of information requested or given. If adequate support is provided to overcome these effects, it allows vulnerable customers to retain their independence, and  fulfils the requirement for “care and consideration” stated in the FCA’s paper.

3. Improve the peopleImprove the people, processes and products that are causing issues or making customers more “susceptible to detriment”. Give staff the flexibility and autonomy to make changes that allow them to provide the “appropriate care” required by the FCA. Simply making information available on the intranet is not enough – the ‘best practice’ case studies in the FCA paper show that the best companies have assessed their barriers and made adjustments on a holistic basis.

4. Extend principlesExtend the principles of the company’s Equality and Diversity policies to your customer base. Embrace diversity and adapt policies so that customers are not automatically disadvantaged or vulnerable at critical times when they need additional support.

Published: 31 Mar 2016
  • Compliance, Regulation & Risk
  • The knowledge

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