Updated: Sep 22
So, you’ve identified a circumstance that you think might be making your client vulnerable. What do you do now?
Here are 5 top tips for the next stage of the process:
1) Is it you, not them?
As institutions and professionals, the way we work can sometimes create a vulnerable circumstance for our clients – this is sometimes known as an institutionally driven vulnerability.
A good example of this is only producing documents in English when a person’s first language isn’t English.
Check to see whether your processes are the things that are creating the vulnerability and if so, explore how you can change these to improve the outcomes for your client.
2) What’s your company policy?
Many firms have policies that identify how to respond and support specific types of vulnerable circumstance such as bereavement. One of the first things you should be doing is checking if you company has provided any guidance as to how to proceed in relation to the identified vulnerability.
3) Existing strategies
Although the existence of a vulnerable circumstance for your client might be news to you, for many of them it will be an on-going situation. It is highly likely that, over time, they will have identified and created strategies to manage the impact of said circumstance.
Take time to explore whether any such strategies exist and how you and the client can utilise them effectively.
4) Utilise your compliance team
Whether a specific policy or not exists regarding a specific vulnerability, it is always worth speaking with your firm’s compliance team (or adviser). As well as being able to offer advice as to how you should manage the situation and support the client in line with the latest FCA guidance, they will also be able to advise you regarding documentation and recording of your actions.
5) Record everything
There’s a saying that goes “If it wasn’t written down, it didn’t happen”. This is never more true when it comes to evidencing how you have identified and supported your vulnerable clients.
Be mindful to record not just how you identified the vulnerable circumstance but also the conversation you have around it’s potential impact on the client; their views on it’s impact; any existing coping strategies; and the discussions with the client as to how to support them going forward.
Whilst identifying financial vulnerability is key to the process of supporting your client, it is only the starting point and the above five tips should help with building the blocks to underpin everything.