RT: There is a risk that people could fall through the cracks.
My view is that we all have the same regulator. Through our summits and our work with advisers, we have been sharing some of the research we have done and the guidance we have created around recognising vulnerability and what sort of solutions we have put in place.
We have created some materials for any advisers but it is important for us as well to learn and to understand from advisers any insights they have around vulnerability.
It's a two-way conversation.
Advisers are trusted by their clients.
We see how the adviser is often treated as an extended member of that person’s family and for us, advisers can help us understand better and well what tailoring and flexibility and solutions would be most appropriate for their clients
It is about having that dialogue and signposting solutions we can offer to help them and their clients on that journey.
FTA: So where do we start?
RT: That's a good question. Vulnerability is broad and, when the guidance first came out from the FCA, it was clear the drivers of vulnerability were great starting points but so much more work needs to be done.
For example, you can't just assume someone is vulnerable, even if their circumstances would suggest vulnerability.
Say someone tells us they are going through a divorce. Are they vulnerable? Is this a vulnerable circumstance? We need to be led by the client.
Clearly, if they are very emotionally distressed, we don't want to walk past that, as we want to help address that situation.
We offer them the option to have someone join the call for emotional support, for example.
But although sometimes there are obvious signs where we need to explore, we cannot assume someone is vulnerable.
The gold standard is where the customers declare to you that they are vulnerable. But that isn't everyone and not everyone will know they are vulnerable.
This is why the research we are doing into vulnerability disclosure is so important, and something we want to share across the industry.
It will help us create context and understand what language we should be using, and how to understand and respond to people's responses on vulnerability disclosure.
Culturally, post Covid, the term 'vulnerable' became more used, and people became more open about it.
Discussions around mental health are becoming more open and that is a helpful milestone towards helping clients with disclosure and with taking them through their journey with us.
