Our regulator, the Financial Conduct Authority (FCA), expects us to identify vulnerable customers, have processes in place to support them and ensure any potential harm is mitigated.
But what does this mean?
Of course, it is always a good idea to stay on the right side of any Government body which could affect our business, but we believe there is a moral responsibility which is much more important.
We are not comfortable with the expression ‘vulnerable client’. It has all too often been a lazy stereotype for old, frail, senile. From my experience, nobody is keen on being labelled in this way, and people may find it difficult to discuss what they are going through due to embarrassment and for fear of judgement.
We prefer to think of it as ‘someone who, due to their personal circumstances, may be especially susceptible to harm’.
Looking at it in this way leads to a spectrum of possible risk. Everyone could potentially become vulnerable at some point throughout their lives.