The guidance reads: “Ultimately, we want to see firms doing the right thing for vulnerable consumers, and embedding this in their culture.”
The FCA has been consulting on this issue with the industry for some time and expects to issue a formal response to the feedback it has received in the first half of this year.
But it is clear that it expects all firms to make efforts to understand the needs of vulnerable clients, to build the skills and capabilities of staff to deal with vulnerable clients effectively, and to design products, services and communication material that meets the needs of vulnerable clients.
It wants advisers to establish an ongoing strategy: to Develop, Monitor, Analyse and Learn.
Being alert
Any client you speak to could currently be going through a period of vulnerability. Be alert to the signs. Things to listen out for include clients:
- Asking you to repeat things
- Responding in an irrational way to simple questions
- Asking irrelevant questions
- Saying ‘yes’ when they clearly have not understood
- Mentioning medication
Sometimes your client will mention that they are having mental health problems or that they have recently experienced a significant life event, such as a bereavement or medical diagnosis.
Note this information so that you and colleagues can plan how to service them better.
Remember, your job is just to recognise vulnerability – not diagnose it.
You do not need to know the exact causes. You have to concern yourself with the problems the client’s vulnerability creates for them. Think about their needs; recognise and adjust.
If you are worried about giving offence, talking about the effects of the vulnerability (that is, the difficulties the client has) and any extra support that is available, will help.
There are obvious other steps you can take to ensure you are addressing the needs of vulnerable clients.
These include speaking slowly, avoiding jargon, listening carefully, holding meetings in accessible locations and arranging meetings around the timing of medication to capture the client when most alert.
Deafness experts suggest that rather than speaking louder, try to speak lower – a lower voice is easier to hear and when we raise our voices we tend to raise the pitch too.
Techniques to consider
For those who want to go further, techniques developed by a number of academic experts may help. These are collated under the acronyms, TEXAS, IDEA and BRUCE.
The TEXAS questioning framework is used by psychologists and counsellors
- Thank them for telling you.
- Explain how the information they have provided will be used (why the information is being collected, how it will help decision making, who the data will be shared with).
- Ask for eXplicit consent to use the information in this way.
- Ask other questions as appropriate (Does your mental health problem affect your ability to communicate with us? Does anyone need to help you with your finances such as a carer or relative?).
- Signpost to internal or external sources of help.
If a client has told you about a mental health issue, a second protocol, IDEA, can be used to manage a more in-depth conversation.
- Impact – Ask what they are finding hard. What has the impact been on their personal and financial situation.
- Duration – When did this start to happen?
- Experiences – How is the client experiencing this vulnerability? Is it something that fluctuates?
- Assistance – Is there anything else we should know about support, treatment or care you are receiving? What do you need to do differently to ensure the best outcomes for their financial wellbeing?
Be aware that for some clients with a mental health issue, their preferred mode of communication may not be face-to-face.
It may not be possible to avoid a meeting, but a subsequent conversation could flow better as a series of emails.
