The COVID-19 pandemic has undoubtedly exposed an increasing number of clients to becoming vulnerable or temporarily vulnerable.
The FCA has continued to set out its expectations that vulnerable customers are to remain a top priority for firms:
- Firms are to provide strong support and service to their customers during the pandemic
- Firms should be proactive in assessing how their customers may be affected by the virus and take steps to help them
- Firms are to use flexibility to support customers
- Firms are encouraged to take initiatives going beyond usual business practices to support their customers.
Types of vulnerability that may become more widespread
Types of vulnerability to be particularly vigilant of in the current climate include:
- Scams and fraudulent attempts that are particularly prevalent during times of market instability, creating unwitting victims of financial crime
- Sudden bereavement – especially given the current social distancing requirements - undoubtedly causing significant distress
- Isolation, particularly in the elderly, that will increase stress and anxiety for many
- People facing unexpected job loss or income reduction who will be looking for urgent support to help them manage short term family finances
- Increased physical, financial or emotional stress suffered by carers or those discharging Power of Attorney
The FCA defines a vulnerable customer 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’.
Proactive client screening
You may want to conduct some screening of your client base for those who may be more susceptible to these vulnerabilities and make proactive contact to ‘check in’ outside of your normal review schedule. For example:
- Those over 70 and living alone
- Those who are self employed
- Those who suffer from, or live with someone who suffers from, ill health.
This type of activity can be evidenced as good practice in response to the FCA’s expectation of firms to provide strong support and service and be proactive in assessing how their customers may be affected by the pandemic
How to spot the signs
Many vulnerable customers would not actually consider themselves to be vulnerable, so it is important to be able to identify potentially vulnerable circumstances, without appearing overly intrusive. Noticing the signs of vulnerability can be difficult, particularly when face to face meetings are not the ‘norm’ in the current circumstances.
Here is a list of things that may help you to spot when your clients are beginning to demonstrate signs that not all is well:
- Having difficulty in taking in information, pre-occupation and possibly lack of perspective
- Struggling to find the time to address important financial planning matters
- Changing attitudes towards taking investment risk
- Suddenly changing their financial plans – requests to withdraw funds that could have detrimental tax implications
- Changing personality, demeanour and use of negative words
- Showing visible signs of anxiety and / or stress
How to encourage disclosure and conversation
Many customers who have become temporarily vulnerable due to sudden changes in circumstances may find it difficult to share and discuss the issues they are facing openly and honestly. Here are tips on how you may want to approach these conversations to make them feel as comfortable as possible:
✔️ Listen actively, to understand, not to second-guess their answers - use your softer, interpersonal skills
✔️ Be as prepared as possible and allow enough time to have a meaningful conversation.
✔️ Use some key conversational techniques:
- Frame the conversation around phrases such as ”Other clients like you are finding the current circumstances challenging”
- Use positive, confident language
- Avoid overload. Keep your advice simple and bitesize
- Give clear reasoning and next steps
✔️ Suggest they get further assistance (if necessary),
✔️ Follow up a day or so later to see how they are doing
There are a few things to try and avoid when speaking with a vulnerable person in distress:
❌ Don't get worked up yourself: remember that the antidote to distress is calm and confidence
❌ Don't rush things: as long as the person is medically stable and safe*, taking your time can help to de-escalate the situation
❌ Don't be dismissive: avoid minimising their concerns or drawing comparisons ("at least you're not...")
❌ Don't make promises you can't keep
❌ Don't assume you know what they need: ask them what they need
*If you are worried the person is not medically stable and safe, we suggest that you call a family member or the Samaritans. If you are worried they are at risk of taking their own life or harming others, call 999 on their behalf immediately.
Expert view from Spill
Will Allen-Mersh from independent counselling provider Spill talks about the five principles of Psychological First Aid that you can apply should you find yourself in a situation where someone vulnerable is in distress.
Expert adviser view
Richard Fraser, Regional Director for Quilter Private Client Advisers and qualified Samaritan, talks about his role at the Samaritans and gives guidance on what you should do if you are particularly concerned about a client’s mental state.
Emotional and practical support for you and your colleagues
We have joined forces with Spill, specialists in workplace mental health support, to offer you and your colleagues access to a wealth of new resources, including qualified therapists.