Guide to advising vulnerable clients

  • To learn what 'vulnerable' means.
  • To understand how firms should identify and deal with vulnerable clients.
  • To ascertain how to communicate with vulnerable clients and other professionals.
Guide to advising vulnerable clients


The Work & Pensions Committee has launched an inquiry into whether and how far the pension freedom and choice reforms are achieving their objectives and whether policy changes are required.

Announced on Wednesday 20 September, this work will follow up an inquiry by the Committee shortly after the reforms were introduced in 2015.

Vulnerability has been at the forefront of regulatory thinking for quite some time, but it does not just affect pensions.

The Financial Conduct Authority (FCA) has defined a vulnerable consumer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”.

This sounds clear enough, but given how quickly a person’s situation can change, how are advisers supposed to keep on top of all their clients? How should they be advising those who might be going through a period of vulnerability that is not expected to be long-term?

Moreover, what happens when the vulnerability comes upon a person almost imperceptibly. What should an adviser look out for? What sort of financial strategies could an adviser put in place to help with long-term financial planning?

This article will examine what is meant by the FCA’s definition and how advisers can work with other professionals to help keep the customer at the heart of the financial planning process.

Contributors to this guide: Keith Richards, chief executive of the Personal Finance Society; Stephen Lowe, group communications director for Just Group; Tony Gammon, director and head of client service at Thesis Asset Management; Claire Trott, head of pensions for Technical Connection; Steven Cameron, pensions director at Aegon; Claire Barker, managing director of Equilaw; Jacqueline Berry, director of My Care Consultant; Nick Telfer, product and marketing director for British Friendly; James Dingwall, chief executive of Thistle Initiatives; Deloitte; the Law Society; the Work and Pensions Committee; and The Financial Conduct Authority.

Simoney Kyriakou is content plus editor for FTAdviser

In this guide


Please answer the six multiple choice questions below in order to bank your CPD. Multiple attempts are available until all questions are correctly answered.

  1. What sort of a state does the FCA describe vulnerability as being?

  2. According to Ms Barker, what should much of firm's response to vulnerability be?

  3. What should be clearly evident in every personal recommendation, according to Mr Richards?

  4. What does Mr Richards say has resulted in additional vulnerabilities linked to divorce?

  5. Ms Berry says there is a real and growing need for a link between what, when it comes to long-term care?

  6. What does Ms Trott say is wise to ensure between all parties?

Nearly There…

You have successfully answered all the questions correctly, well done!

You should now know…

  • To learn what 'vulnerable' means.
  • To understand how firms should identify and deal with vulnerable clients.
  • To ascertain how to communicate with vulnerable clients and other professionals.

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