RegulationApr 20 2020

Drawing up a policy for vulnerable clients

  • Describe the importance of having a vulnerability policy
  • Explain what a vulnerability policy is
  • Describe how to keep it foremost in people's minds
  • Describe the importance of having a vulnerability policy
  • Explain what a vulnerability policy is
  • Describe how to keep it foremost in people's minds
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CPD
Approx.30min
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CPD
Approx.30min
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CPD
Approx.30min
Drawing up a policy for vulnerable clients

The issue with piecemeal approaches is they may have different objectives, and will inherently result in an inconsistent approach to vulnerability.

They may also have been developed out of a controlled environment, so the quality or appropriateness of these piecemeal policies cannot be guaranteed.

Getting this overview will also have the effect of teaching you where your company already has made progress.

A team might already have an effective method of identifying vulnerabilities, which can be rolled out across the company, even if they do not have a formal policy.

Speaking to staff will also identify where there are pressure points the policy should look to alleviate. 

Defining vulnerability

Key to a vulnerability policy will be two definitions.

One is how you define vulnerability.

The FCA’s definition of vulnerability is: “A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

Firms regulated by the FCA should consider using this.

A second definition will be what success looks like.

What are your aims for the policy?

This way you can measure how successful the policy is in order to improve it.

Examples may include a reduction in complaints, an improvement in client satisfaction. Or it could be greater engagement from a certain type of client.

Remember, a vulnerability policy is not the finish line - it should be monitored and improved over time, so having some measurable parameters will be helpful.

As a baseline, a policy should contain guidelines for staff - from the managing director to new recruits - in how to best identify and support vulnerable clients, as well as examples of best practice. 

This should include formal, regular training for everyone on incorporating the policy into their day-to-day interactions.  

It should also include practical tips which staff can follow.

The Money Advice Trust has several tools and tips on this, including the BRUCE protocol, which can be used by frontline staff to identify clients who may be struggling with mental health issues: 

Behaviour - is the client’s behaviour and/or speech indicating a difficulty in remembering or understanding?

Remembering - Does the client have a problem with memory or recall?

Understanding - Can the client understand the information given to them?

Communication - Are they able to communicate their thoughts, questions and decisions?

Evaluation - can the client ‘weigh up’ the different options?

There are plenty of third parties such as the Money Advice Trust who have in depth resources to help with the development of the guide, and where appropriate reference or incorporate them in your policy.

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