The key principle of the new Consumer Duty is to secure good outcomes for customers. Alongside preventing customer harm we need to be actively giving customers opportunities to achieve their financial goals, making sure every customer, especially those who are vulnerable, experience good outcomes.
So, what is a vulnerability?
A vulnerable customer can be anyone, at any point in their life. It’s important to remember that vulnerabilities go beyond physical and mental impairments and are not always permanent - events in our lives can impact us and change our needs too for the short or the long term. I discuss this in more detail in my article Vulnerable Customers and Consumer Duty.
Some clients in vulnerable situations we’ve supported might have:
- a long-term illness
- relationship breakdown
- English as a second language
- hearing impairment
- recent bereavement
What steps have we taken to help our customers?
Our Client Services and Operations teams have been working extremely hard to adapt our processes and train their team members on how to help clients with vulnerabilities in a sensitive and fair way.
Logging vulnerabilities:
The teams log any vulnerabilities on their system, so anyone who has contact with the client will be aware of their situation so will be suitably equipped to help them.
Regular training:
The teams receive regular training on how to work with clients with vulnerabilities. From identifying and logging the vulnerability correctly, to understanding the best communication method to use when communicating with the client, whether that’s by phone, email or letter.
Adapting processes:
Something as simple as extending a timeframe or accepting digital signatures can go a long way to helping a client feel understood and provided for. We regularly look at how we can help clients complete the processes we need in the easiest way for them.
Vulnerable Clients Working Group:
We’ve created a Working Group, made up of people from across our organisation, whose focus is to carefully consider how we can improve our processes so we can give vulnerable customers the best level of service.
Here's a couple of examples of how we've recently helped our clients:
Transitioning from Junior ISA to adult ISA
A client held a Junior ISA (JISA) with Parmenion and as they turned 18 years of age, our automatic process of transitioning the account into an adult ISA began.
What was the vulnerability?
The 18 year old’s adviser let our Client Services team know their client has a physical and verbal disability which means they weren’t able to complete and sign the information form we need to complete the transition. They also told us they were in the process of setting up a Power of Attorney so a family member could communicate with us on the client’s behalf.
What steps did we take to help?
We immediately logged this vulnerability on our system so our team members could act with appropriate care whenever we were in contact with this client. We also raised this vulnerability with our Working Group who approved a 90-day extension on the account so the family had more time to arrange the Power of Attorney.
A long term condition
One of our clients has a long-term condition that makes it difficult to write, so they struggle to sign a consistent signature.
What steps did we take to help?
So far, the client hasn’t needed to give a hand-signed signature but working with this client prompted us to consider what we could do to help in the future. We started working with our colleagues in the Compliance team to find alternative ways to get a client’s authorisation, without compromising security. So, if the time comes, we can give a vulnerable client the option to give an instruction without having to physically sign for it.
These are just some of the steps we always take to help our customers when they’re in a vulnerable position. Having staff who are trained and aware of all types of vulnerabilities and what can cause someone to be vulnerable, even for a short period of time, means we are able to adapt and support our clients and make their journey with us easier.
Leah Wilkins, Head of Client Services Intermediary
This article is for financial professionals only. Any information contained within is of a general nature and should not be construed as a form of personal recommendation or financial advice. Nor is the information to be considered an offer or solicitation to deal in any financial instrument or to engage in any investment service or activity.
Parmenion accepts no duty of care or liability for loss arising from any person acting, or refraining from acting, as a result of any information contained within this article. All investment carries risk. The value of investments, and the income from them, can go down as well as up and investors may get back less than they put in. Past performance is not a reliable indicator of future returns.
