Vulnerable customers

At the West Brom for intermediaries, we are committed to providing fair and appropriate treatment to all of our customers. This commitment to treating customers fairly forms the basis for everything we do. This includes providing support for customers that we understand or reasonably suspect to be vulnerable.

Whilst we know you’ll have your own policies for supporting vulnerable customers, we wanted to provide an overview of vulnerability and how to let us know if your client needs extra support.


What is a vulnerability?

Vulnerability can come in a range of guises and can be temporary, sporadic or permanent in nature.

The FCA defines vulnerability as ‘someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care’.

The Consumer Duty requires firms to deliver good outcomes for customers - we must act in good faith and avoid causing our customers foreseeable harm. The Duty is therefore, key to how we also support our vulnerable customers to ensure they receive a service as good as customers who aren’t vulnerable.

It is therefore the duty of our staff and intermediary partners to understand, and if necessary, act upon this guidance. By ensuring that the utmost is done to support vulnerable customers appropriately, we can be safe in the knowledge that their best interests are always at the heart of what we do.


Key drivers of vulnerability

The FCA has identified the following four key drivers of vulnerability which are shown below.

Health
Health conditions or illnesses that affect ability to carry out day-to-day tasks		 Live events
Life events such as bereavement, job loss or relationship breakdown		 Resilience
Low ability to withstand financial or emotional shocks		 Capability
Low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy or digital skills
  • Physical disability
  • Severe or long-term illness
  • Hearing or visual impairment
  • Mental health condition or disability
  • Addiction
  • Low mental capacity or cognitive disability
  • Retirement
  • Bereavement
  • Income shock
  • Relationship breakdown
  • Domestic abuse (including economic control)
  • Other circumstances that affect people’s experience of financial services e.g. leaving care, migration or seeking asylum, human trafficking or modern slavery, convictions
  • Inadequate (outgoings exceed income) or erratic income
  • Over-indebtedness
  • Low savings
  • Low emotional resilience
  • Low knowledge or confidence in managing finances
  • Poor literacy or numeracy skills
  • Poor English language skills
  • Poor or non-existent digital skills
  • Learning difficulties
  • No or low access to help or support


Identifying a client’s vulnerabilities

Depending on whether your meeting with a client is over the telephone or face to face, it can be tricky to identify a client’s vulnerabilities when they’re not visible e.g. blindness or physical disabilities. Some examples of things you can look out for are:

Your client may say You may observe Other signs
  • I don’t understand the information you’ve sent to me
  • I’m having a few problems
  • Can you explain that again
  • I can’t afford those payments
  • I’m ill or my partner is ill
  • Signs that your client has not understood or signs of confusion
  • Shortness of breath or signs of agitation
  • Not remembering something you’ve talked about previously
  • Letters or information has been provided/written by somebody else on their behalf


What to do if you’ve identified a vulnerable client

If a client has disclosed information about their circumstances, or display any personal characteristics which you consider could make them vulnerable, then please call our Intermediary Sales and Support team on 0345 241 3597 as soon as possible. We will ensure that any information provided is recorded accurately to assist us when dealing with them.

Alternatively, if your client would prefer to let us know, they can complete our Additional Support form available on our consumer website. This form will be submitted to our Mortgage Support team who will update your client’s account and ensure we provide them with the appropriate level of support.