Vulnerable Clients 4. Capability

In February 2021, the Financial Conduct Authority issued guidance to financial firms called “Fair Treatment of Vulnerable Clients”.  It also set out the key drivers of vulnerability:

1. Health
2. Life Events
3. Resilience
4. Capability

Whilst we have always worked and offered services to consider all clients potential vulnerabilities.  Now that the FCA has documented the same, we are endeavouring to make continued improvements for staff awareness, identifying vulnerable client positions and offer guidance on the same to ensure the best outcomes for you on financial wellbeing.

Capability – What factors do we take into account when assessing your capability to understand financial risks, decisions, products and services?

The FCA has set out some key capability factors that we consider for each client when offering financial advice:

• 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

As part of our discussions with clients we question and become aware very quickly where clients have areas with weak or low capabilities and we always take these into account when dealing with your finances, such as:

• Low knowledge or confidence in managing finances – we will fully discuss needs and requirements without jargon and ensure any verbal or written suggestions are make within your financial services knowledge and experience.  We are also required under the FCA’s PROD (Product Intervention and Product Governance Sourcebook) to ensure that all products and services are categorised for use with only clients that have capability.
• Poor literacy or numeracy skills – we are not all mathematicians, so we will always take time to ensure you have a greater understanding, in plain English terms.
• Poor English language skills – as you would expect, we also try to deliver advice in plain English or in ways that you would understand, we try and relate matters that we are working on with examples from your daily living or experience to illustrate unfamiliar concepts.
• Poor or non-existent digital skills – where possible, if a client has limited digital access or knowledge, we will issue in other formats such as paper or pictorially to get the message across or to make services more accessible.
• Learning difficulties – this can be difficult for all, where possible when we perceive there to be learning difficulties, we try and get close family or friends involved to act as advocates or attorneys or simply to be there with you to ensure your best interests are concerned.  We will also research or talk to relevant support groups or are specialists in that particular field of learning difficulty to try and get guidance or tips on how best to service a client with a particular difficulty. 
• No or low access to help or support – as with the above, will also research or talk to relevant support groups or are specialists to try and get guidance or tips on how best to service a client with a particular difficulty or signpost you to support groups that may be able to assist you. In addition, your local library can be a free and easy way to access a computer or get some basic digital skills.  Practice breeds confidence.

For example, when looking at poor digital skills:

We understand there are many causes as to why people lack digital skills such as age, poor hearing, poor sight, poor education, fear of technology, fear of scams and online safety, lack of access to computers or smartphones.  We cannot tackle all of these, but we are trying as are many financial institutions such as banking groups offering Digital Skills Mentors and colleges offering adult education courses.

It may even be family and friends that best show/teach you how to do some basic things, even just to pique your interest.  We all learn more when we are interested in any topic.  For example, if you have a favourite sport or hobby, it may help for family or friends to get you online and just getting used to reading football reports or watching the latest sewing techniques or recipes on YouTube.

Certainly, wherever we have online forms or questionnaires, we always produce Guidance Notes and Guidance Videos to help using our online tech, but we suppose this needs to start at a more basic level for those who really do fear digital technology.

The reality is it can even be down to a fear for your security.  Again, we try in many communications, to explore and explain the security built into our technology, up to bank grade security, to protect your financial information. 

Financial Education

Our websites have over 10,000 pages and nearly 1,800 videos that we have written and filmed over the years to try and help people with understanding many areas of finance.  We do both written and verbal to account for both physical disablement such as sight, hearing or speech but also the fact that you are able to access this all 24 hours a day, so you can repeat, playback, read again, ask us etc to ensure greater financial capability.

Our ongoing plan is to always build services and systems designed to make you ever more confident when using our digital services.