FCA & Consumer Credit Regime DWF help you navigate through the changes.


Vulnerability – 21 questions, 21 steps!

In March 2017 the Finance and Leasing Association together with The UK Cards Association published “Vulnerability: a guide for debt collection – 21 questions, 21 steps” 

The purpose of the guide was to provide new insight, data and recommendations for organisations working with vulnerable customers. Data was gathered from approximately 1600 staff working in the collections industry and presented through “21 questions”.

Messages from previous papers on vulnerability are reinforced and the guide also introduces some new tools. Lenders and collections teams should, by now, be well acquainted with protocols such as TEXAS and CARERS. The new protocols set out are to help frontline staff go further in dealing with vulnerable customers:-

BRUCE – to help staff identify limitations and potential vulnerabilities

SPIDER – to help staff in breaking bad news to customers

BLAKE – to help staff deal with customers at risk of suicide

The guide provides a vast amount of information and should be at the top of any lenders agenda on vulnerability. Arguably, the most important step within the guide is step 21 “Taking action”.

The emphasis in this step is for lenders not only to recognise that action is needed but to employ the necessary techniques and tools to address the action points. The guide encourages lenders to be open about vulnerability and to share their experiences so that an environment “focused on the practical rather than the principled” is created.

Lenders should see the guide as an opportunity to take stock of where they are and where they want to be in dealing with vulnerable customers. Current policies and processes should be reviewed and lenders should consider what additional training and new initiatives are required to implement the practical guidance the paper provides.

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Vulnerable Customers

“Vulnerability” cannot be ignored. With the FCA stating that “most users of consumer credit may be regarded as “vulnerable” to some degree because of their financial circumstances”, this is an area firms must not get wrong.   Are you providing your vulnerable customers with adequate safeguards?  The FCA promises proactive supervision of firms in this area.

Staff should receive specific training in this area and firms must have proper documented processes and procedures to ensure compliance.

Download our “Top Tips for dealing with Vulnerable Customers, to help you understand what is required under the FCA requirements.

Read our blog posts on vulnerable customers

Online Courses

Find out more about our Vulnerable Customers and Mental Health e-learning modules, part of the DWF Conforma product »

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FCA & Consumer Credit Regime DWF help you navigate through the changes.