Let's talk about customer vulnerability

There was a lot for both lender and broker to consider when the Consumer Duty rules were implemented in August last year. As Consumer Duty champion for the intermediary side of the business, and member of several working groups, it was great to see collaboration from all parts of the industry to ensure the key elements of the rules were embedded.

There was also recognition that as an industry we were, in the main, in a good place in providing good outcomes for customers. One of the main strands that runs through Consumer Duty is the dealing with customers that could be considered as vulnerable. For me, this is the area that provides our biggest challenge, a year on from implementing Consumer Duty.

The recognition of and providing the support for, a Vulnerable Customer is fundamental to us, ensuring that we give everyone the best experience when considering a mortgage.

So, who is vulnerable?

The FCA describes an individual with a vulnerability as ‘someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care’.

Whilst we have a definition, it can be hard to recognise vulnerability and we certainly don’t want to pin a badge on someone. The physical characteristics may be easier to recognise and support. Someone with visual & hearing impairment for example, but how do we support those that have been affected by a life event or have low resilience or capability?

Based on the low numbers that have been highlighted to us as a lender over the last 12 months, it’s clear that we need to do more as a lender to support you with vulnerable customers.

So, what are we doing as a lender?

• At Skipton we have provided a broker guide on Supporting Customers with Additional Requirements
• We are reviewing our application process to make it easier for you to provide information on your customer and allowing you to highlight what additional support they may need?

Finally, I feel that as lenders and brokers we just need to talk about this complex subject more. We know that no-one is in a better position to understand the requirements of a potential borrower than a broker, and as a lender we need to better highlight what we can do to support you.

To that end, I have recorded some ‘mini-conversations’ with our Vulnerable Customer team which we will share on LinkedIn. We may not have all the answers, but we thought we would share our thoughts on various topics, like how to have a conversation and address some myth-busters about what a lender would do with this information.

The short clips are aimed at starting the conversation around customer vulnerability and we would be more than happy to take any feedback and suggestions on where the conversations should go next.

Let’s talk.