Protecting Vulnerable Customers
At NorthStar Wealth Management, we are committed to protecting vulnerable customers. To this end, we have devised this ‘Vulnerable Customer Policy’. The aim of this policy is to outline the practice and procedures to contribute to the prevention of detriment to clients who find themselves in vulnerable circumstances. This policy covers all NorthStar team members and areas of work directly with customers.
Definition of a ‘Vulnerable Customer’
The Financial Conduct Authority in its publication Consumer Credit and Consumers in Vulnerable Circumstances (April 2014) defines customers in vulnerable circumstances as follows:
“We consider a vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment.” With the most significant detriment occurring when, “…through the use of consumer credit, they get into unmanageable or problem debt.”
Customers who might be considered as being in vulnerable circumstances could include:
- Customers with mental capacity deficiencies
- Customers who are ‘financially unsophisticated’ or have low ‘financial literacy’
- Customers with a low income
- Customers already in a distressed financial situation
- Customers with language and communication problems
Identification of Vulnerable Customers
It is important that potentially vulnerable customers are identified to ensure procedures are put in place to help. This means providing additional information, guidance and support to enable them to make an informed decision.
It is critically important to listen carefully to all customers and to identify people who may be classed as a vulnerable customer.
Some key aspects to look for when identifying a potentially vulnerable customer:
- An inability to hear or understand what is being said
- Repeated questions of a similar nature
- Inconsistent comments or answers
- A seeming lack of understanding of the nature of conversations
- Body language signs
In addition, we consider anyone who is ‘financially unsophisticated’, has low ‘financial literacy’, a very low income or is in ‘financial distress’ as a potentially vulnerable customer. These aspects are typically covered during the fact finding process at our Discovery Meeting with the customer.
Steps to Take When Dealing With Vulnerable Customers
If any member of the NorthStar team feels they are dealing with a potentially vulnerable customer, they should report this to a member of the management team immediately.
Following internal discussions, where a vulnerable customer is identified, this will be recorded on the customer file. A plan will be put in place to help the vulnerable customer. This will be on a case-by-case basis with the requirements dependent upon the specific circumstances of the vulnerable customer.
Steps that may be put in place include:
- Providing additional opportunities for the customer to ask questions about the information we have provided
- Seeking additional confirmation that the customer has understood the information that has been provided
- Asking if there is anybody with them who is able to assist the customer, and offer them the opportunity to have a family member or friend present during the conversation
- Offering the customer the opportunity to complete the transaction after a period of further consideration
- Recommend the customer use a competent translator if language is an issue.
- Recommend the customer grant a ‘Power of Attorney’
All members of the NorthStar team dealing with a vulnerable customer have an ongoing duty to report any changes in circumstances or concerns to a member of the management team. In these circumstances, the plan in place should be considered for revision.
To ensure our duties are met in relation to protecting vulnerable customers, the senior management have the following responsibilities:
- To ensure all members of the NorthStar team are aware of this policy and are adequately trained
- To provide a means of reporting any instance where a potentially vulnerable customer is identified
- To support anyone identified as a vulnerable customer
The responsibilities of all NorthStar team members are:
- To be familiar with this policy and procedures
- To report any instances where they believe a customer may be vulnerable to the management team
- To take appropriate action in line with this policy where necessary
Should you require more information about our Vulnerable Customers Policy, or anything else covered on this page, please contact us.