• Chris Pedel

Vulnerable Client Policy

It is complex to identify a vulnerable client as there are many different situations; the vulnerability may not be permanent and not everyone becomes vulnerable in the same way. Clients could potentially be vulnerable through any of the following circumstances,

1. Physical/mental impairment-this may be age related but not necessarily

2. A severe illness, this may be short term or long term. For examples, consider MS, Motor Neurone Disease and Parkinson’s

3. Client having a caring responsibility

4. Lack of financial resilience or income shock

5. Life Events-such as Bereavement/Retirement/Relationship breakdown

6. Lack of support structure

7. Having non-standard requirements such as ex-offenders, care leavers, refugees

8. Under influence of someone else

9. Poor literacy or numeracy skills

10. Hearing impairments

11. English not first language

12.Low mental capacity or cognitive disabilities

13. Low knowledge in financial matters

An FCA Occasional Paper No.8 considered Consumer Vulnerability in February 2015 and estimated that approximately 50% of UK adults display characteristics of being potentially vulnerable.

Under the Mental Capacity Act 2005 as amended under the Mental Capacity (Amendment) Act 2019, there are two important definitions,

Capacity-Does the client have capacity to make a decision, this may depend on the decision and remember that the capacity may fluctuate

Capability-Does the client have the potential to understand or learn with the right support

Important Principles under the Mental Capacity Act 2005 as amended, are as follows,

· There is a presumption of capacity unless proved otherwise

· Do not treat people as incapable of making a decision, support capacity

· Individual has right to make unwise decision

· Always do things or take decisions for people without capacity in their best interests

· Before doing something for someone, consider whether outcome can be achieved in a less restrictive way.

All of the above needs to be considered when assessing a client, this is an important soft skill.

Our Policy

We need to ensure the following,

· We recognize when somebody is vulnerable

· That we can deal with them flexibly

· We make our service clear and easy to understand and access

· Costs are clear and transparent

· We treat the client fairly


All staff need to be able to understand what a vulnerable client is and then be able to identify a vulnerable client from our records. It is important that all staff read this policy to raise awareness and ensure the procedure is complied with.

If you feel a client may be vulnerable, discuss with the adviser so that a decision can be made as to whether to treat the client as a vulnerable client or not. Rather than including this information on a Fact Find, if the adviser wishes a client to be treated as potentially vulnerable, they will make a file note for the file. Once a client is identified as vulnerable, their details can be updated on our computer records to show this.

Once a client has been identified as vulnerable, there are various actions that must be taken to ensure the client has understand as follows,

1. If a face to face meeting has been held, follow up with a telephone call to ensure what was discussed has been understand

2. When a letter is sent, follow this up with a phone call to ensure letter has been understood

3. In respect of letters, remember the following,

- Use shorter sentences

- Avoid jargon

- Make bullet points

- Make main points at start of letter and keep detail in the appendix

- Use larger font, if appropriate

4. Offer the client a choice of communication

5. Check whether anyone else can offer support to client, this may not just be family but include specialist services

6. Consider when making home visits, doing this in stages “manageable chunks”

7. Make sure you maintain the right tone and pace when speaking with the client, either face to face or by telephone

8. It may not be appropriate to direct vulnerable clients to online channels, but instead read out information to them

9. Encourage client to put a power of attorney in place (remember there are the two sorts, one for property and affairs and one for health and welfare) for when the client may lack mental capacity. If the client has lost mental capacity and there is no power of attorney in place, a close relative or professional can apply to the Court of Protection under a deputyship order

10. If it is not appropriate to proceed with the service/business as the client does not have the capacity (even with support) to make the decision and there is no power of attorney in place to deal with property and affairs, do not proceed. If you have concerns about the client, see if either family or specialist services can offer support.

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