A few weeks after my father died, I decided to have all my long hair cut off. I cried for hours afterwards, I was clearly in no place to make such a major decision, but thankfully hair grows back. Financial decisions on the other hand can be long lasting. Nobody wants to think of themselves as vulnerable but at some point in our lives unless we are extremely lucky life can throw a curve ball which means our decision making can be impaired.
As our clients grow older, some of them are at risk of increased vulnerability, but by no means all! A change towards vulnerability can happen at any age. It can be subtle. It can happen quickly or slowly over a long period of time. We want people to have autonomy where they can, but we take special measures to protect our vulnerable clients.
Vulnerability continues to be a priority for the Financial Conduct Authority, and is a key area of focus for us at FMB.
There are four key drivers which can lead to increased risk of customer vulnerability:
- Health - conditions or illnesses affecting a customer’s ability to carry out day-to-day tasks
- Life events - such as bereavement, job loss or relationship breakdown
- Resilience - low ability to withstand emotional or financial shocks
- Capability - low knowledge of financial matters or low confidence in managing money (financial capability). Or low capability in other relevant areas such as literacy or digital skills.
- These drivers can impact people of all ages and wealth.
All clients have a risk of becoming vulnerable and fall within a spectrum of risk from low to high:
- Clients at one extreme are less likely to be vulnerable and therefore face a lower risk of harm.
- At the other extreme, the risk of harm is greater and clients are more likely to have different needs, for example multiple overlapping characteristics of vulnerability.
It’s important to identify the needs of all clients along this spectrum and respond accordingly. For example, a client who’s lost their job or falls ill is likely to have different or more needs than others. If these aren’t met, they may be vulnerable to harm. If they also have low resilience or capability, they’re likely to need more support and can be at greater risk of harm if they don’t receive it.
Clients at the greatest risk of harm are likely to require more, or different, support than others.
Steps we take:-
- Vulnerability is everyone’s responsibility at FMB.
- Age does not automatically mean vulnerability.
- Treat people individually, show respect and listen to what they say.
- Be vigilant - watch out for coercive behaviour and check body language.
- Always assess the needs of older and vulnerable clients when arranging meetings and providing information.
- Make adjustments when dealing with clients who have other needs - such as a hearing impairment, a disability, or medical condition that affects their ability to concentrate.
If something doesn't feel right, we discuss it with our manager because it is better to be cautious and safeguarding is of key importance. We recommend clients have Lasting Powers of Attorney which can be invaluable. If you would like to discuss any of the issues I have mentioned, please do not hesitate to contact us.
FMB is proud to be a member of the Vulnerability Task Force.
- Ruth Power, FMB Director of Business Development