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Vulnerable Client Training
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Vulnerable Client
TRAINING
INTRO
Why is it important?
INTRO
DEFINITION OF VULNERABLE
Vulnerability Definition
The FCA defines a vulnerable client 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’.
DETRIMENT
DETRIMENT
Detriment is essentially any disadvantage a
client could suffer, for example this could
range from being treated unsympathetically by
a member of the team firm or choosing the wrong
investment product. This can occur in
particular with vulnerable clients because
financial products can be relatively complex
and, in certain cases, may not be optional.
We must be mindful that many clients in
vulnerable situations may not think of
themselves as being ‘vulnerable’.
RISK FACTORS
IDENTIFYING VULNERABLE CLIENTS
IDENTIFYING VULNERABILITY
- Low Literacy/ Numeracy skills
- Suffering from a long term illness
- Physical Disability
HEALTH & AGE
- Mental Health Problems
- Elderly
- Young/ Inexperienced
CIRCUMSTANCE
- Changes in circumstances (for example, divorce)
- Unexpected changes in circumstances (for example, being made redundant, bereavement, being diagnosed with a long term illness)
- Low income and/or debt
- Caring responsibilities (including operating a power of attorney)
- Lack of English language skills
- Not possessing standard documents or credit history (for example armed forces personnel returning from abroad, ex-offenders, care-home leavers).
- No Internet Access
DEALING WITH VULNERABLE CLIENTS
IDENTIFICATION PROCESS
Once identified as having a risk factor the service log should be updated to note that the client is vulnerable
File notes should be made and added to VC about when and how the vulnerability was identified, where possible using the clients own words Record only factual information and not opinion. CSA must contain GDPR personal data section.
Where a Power of Attorney or Deputy Order is in place we will obtain copies of AML verification from attorneys and deputies, and ensure that Powers of Attorney/ Deputy Orders are genuine.
We are all responsible for the wellbeing of our clients.
CLIENT INTERACTION
- Front line Staff are crucial to a customers experience.
- Treat every client as an individual and with respect.
- Invite client to have a family member/third party attend meetings
- If there is concern of coercion from family, endeavor to meet clients on their own to assess the circumstances.
- Limit meetings to no more than 1 hour for clients who may become overwhelmed or struggle to process information.
- Offer additional meetings to discuss recommendations and give the opportunity for third party to attend.
- Communication Options and Large Text Available
TEXAS
RISK LEVELS
The severity of the clients situation will influence the measures we need to take.
This could range from observation and open questioning, to recording specific information the affects how we deal with that client to emergency situations that require intervention.
CONCERN
RISK
CRISIS