Vulnerable Consumer Policy
Overview
Ingenious Financial Solutions has established clear and effective policies and procedures for identifying and dealing with vulnerable customers.
The Consumer Duty requires firms to treat all customers, including those with characteristics of vulnerability, fairly. This includes proactively identifying vulnerabilities, designing suitable products and services, and providing appropriate support to achieve good outcomes.
Definition of a Vulnerable Consumer
“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”
Commitment to Vulnerable Consumers
Protecting vulnerable consumers is a key priority. The firm aims to ensure that outcomes for vulnerable customers are as good as those for other customers.
Fair treatment is embedded across the firm’s culture, policies, and processes throughout the entire customer journey.
Approach to Vulnerability
Vulnerable consumers may have reduced ability or willingness to make informed decisions and may be at higher risk of harm.
The level of care provided is adapted accordingly.
Fees Policy
The firm does not charge upfront fees for:
| Service Type | Fee Policy |
|---|---|
| Credit or mortgage-related work (vulnerable customers) | No upfront fees |
| Credit broking services | No upfront fees |
Staff Training
All staff, including non-customer-facing employees, receive training on identifying and supporting vulnerable customers and must pass relevant assessments.
Key Drivers of Vulnerability
The firm has identified four key drivers that may increase vulnerability:
| Driver | Description |
|---|---|
| Health | Conditions affecting ability to carry out daily tasks |
| Life Events | Events such as bereavement, job loss, or relationship breakdown |
| Resilience | Low ability to cope with emotional or financial shocks |
| Capability | Low financial knowledge, confidence, or skills (including literacy and digital ability) |
Consumer Classification
Customers are assessed and recorded into one of three categories:
| Category |
|---|
| Not vulnerable |
| Potentially vulnerable |
| Actually vulnerable |
This classification is recorded for audit purposes and reviewed where appropriate.
Characteristics of Vulnerability Drivers
| HEALTH | LIFE EVENTS | RESILIENCE | CAPABILITY |
|---|---|---|---|
| Physical disability | Retirement | Inadequate or erratic income | Low financial knowledge/confidence |
| Short or long-term illness | Bereavement | Over-indebtedness | Poor literacy/numeracy |
| Hearing or visual impairment | Income shock | Low savings | Poor English language |
| Mental health condition | Relationship breakdown | Low emotional resilience | Poor digital skills |
| Addiction | Domestic abuse (including economic control) | ||
| Learning difficulties | Caring responsibilities | ||
| Low mental capacity | Other circumstances (care, asylum, trafficking, convictions) | ||
| Limited access to help/support |
Ongoing Assessment
Where there is an ongoing relationship, vulnerability is reassessed at each meeting involving advice or decision-making.
Support Measures
Customers are encouraged to:
| Support Type | Details |
|---|---|
| Accompanied meetings | Bring a family member or trusted representative |
| Financial discussions | Consult trusted individuals before decisions |
| Additional time | Given to ensure understanding and decision-making |
| No pressure | Clients are never pressured into decisions |
Assessment Process
The firm determines vulnerability through:
| Method |
|---|
| Careful client interviews |
| Fact-finding processes |
| Risk assessments |
The firm will not proceed if a customer is identified as vulnerable without adequate support.
Equality and Fair Treatment
The firm complies with obligations under the Equality Act 2010 and ensures fair treatment for all customers.
Record Keeping
Specific customer requests and needs are recorded to ensure ongoing support and appropriate service.
Ongoing Communication
The firm encourages regular contact and updates from clients regarding any changes in circumstances.
Proactive communication is maintained where there is an ongoing relationship.
Scam Awareness
Customers are encouraged to remain vigilant against scams and seek guidance from trusted resources such as Friends Against Scams, a National Trading Standards initiative aimed at preventing fraud and protecting individuals.
