TECHNICAL TALK
WHEN WE LOOK AT PRACTICAL WAYS FIRMS AND ADVISERS CAN DEAL WITH VULNERABLE CUSTOMERS , I FEEL A GOOD STARTING POINT IS UNDERSTANDING THE DIFFERENT TYPES OF VULNERABILITY .
of vulnerabilities . This article is not designed to provide you with the skills to apply these in practice but simply to make you aware of some of the approaches that you can take . The use of these theories is often recognised by way of their acronyms and includes :
• BRUCE – When your client has mental capacity limitation
• IDEA – When talking to a customer about their situation or health condition
• TEXAS – To gain consent to record sensitive information shared by your client
Each of these theories adopt a different type of questioning to understand , interact and support people in areas of health and mental health . You can find out more about these academic theories in the Vulnerable Clients Guide that is available in our online Vulnerability Hub . The regulator has reinforced the importance of embedding the fair treatment of vulnerable customers within a firm numerous times , and also that all relevant staff should understand how their role affects the fair treatment of vulnerable customers . The regulator ’ s expectations for relevant staff within a firm are :
• ensuring that frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability
• offering practical and emotional support to frontline staff dealing with vulnerable customers .
I also believe that requiring staff to undertake training around the fair treatment of vulnerable customers is an excellent way for Senior Managers at a firm to demonstrate that they have taken reasonable steps to embed it into their firm ’ s policies and culture . You can find our online vulnerable clients skills training in our Vulnerability Hub . Dealing with vulnerable customers can be a complex area and some clients experiencing certain types of vulnerability may need specialist support , either in the long or short term . We have details of , and resources and support material from , third-party organisations which provide expert advice and guidance that are also available in our Vulnerability Hub . You may also have heard of the Financial Vulnerability Taskforce , which is an independent professional body covering the personal finance , insurance and wider financial services sector . Its purpose is to promote greater understanding , encourage appropriate behaviours and establish good practice in respect of consumer vulnerability . The Financial Vulnerability Taskforce website has a wealth of information and has a resource library where you can find useful material and support related to vulnerability . We know that the fair treatment of vulnerable customers is a key area of focus for the regulator , and they have produced a lot of guidance for firms , but we also know that the FCA has not – and will not – make specific rules to address each area of vulnerability . The FCA guidance does not cover every scenario and does not really provide firms with potential responses to assist firms at a client level . As a result of this I would recommend firms utilise the wealth of support and resources out there from organisations like the Financial Vulnerability Taskforce , and ensure they undertake staff training in this area .
You can find our Vulnerable Clients Hub in the Compliance area of the SimplyBiz and Compliance First websites , or you can speak to our Compliance team for more information on 01484 439120 . To read more about the Financial Vulnerability Taskforce , visit www . fvtaskforce . com
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