What is a vulnerable customer – and how can you protect them?

This is a summary of an article by our credit partners at TransUnion. To read the full article, please click here.

 

Continued and relentless macroeconomic turbulence across the 2020s, including high interest rates, record high food and goods prices, worldwide political and social upheaval, and even the backlogs of NHS appointments, have caused stress for consumers in the UK, calling for them to have a high level of endurance and resilience.

 

StepChange’s personal debt statistics reveals that the ‘cost of living increase’ is now the most common reason for debt, cited by one in four (25%) of their clients.

 

What is a vulnerable customer?

 

Supporting vulnerable customers is nothing new – what is more recent is the shift regulators are taking to outline in greater detail their expectation that firms must take greater responsibility and accountability for preventing consumers at risk of vulnerability from harm.

 

Whilst also advising firms to be more inclusive towards vulnerable consumers, offering them greater choice and empowerment than before, rather than purely making ‘responsible adjustments’. This is evident in the FCA’s Consumer Duty guidance which specifically calls out with greater emphasis the need to support vulnerable customers in addition to treating all consumers fairly.

 

4 key drivers of vulnerability outlined by the FCA:

 

– Health – health conditions or illnesses that affect the ability to carry out day to day tasks

 

– Life events – major life events such as bereavement or relationship breakdown

 

– Resilience – low ability to withstand financial or emotional shocks

 

– Capability – low knowledge of financial matters or low confidence in managing money

 

How to identify customers showing signs of financial vulnerability with data indicators

 

Consumers make multiple transactions and interact with several businesses; few solely transact with one credit provider. Relying purely on the transactional data you hold on an individual customer is a miss as you’ll only see your piece of the puzzle.

 

By zooming out to see a fuller data picture of consumers, you can identify financial stresses affecting their situation.

 

What are the indicators of financial difficulty?

 

Financial difficulty in indicator form looks like:

 

-missed payments on mainstream credit

 

– utilities arrears

 

– defaults, late payments and arrears

 

– forbearance on credit

 

– debt management plans

 

– County Court Judgments (CCJs)

 

– insolvencies.

 

Indicators of non-financial vulnerability

 

Non-financial vulnerability by its nature is not as overtly obvious in the data as financial vulnerability, but there are signs that, once captured, can be used to provide an even more detailed data picture of your consumers, adding new dimensions to your treatment strategies.

 

These signs could include:

 

– Cognitive vulnerabilities – mental health, gambling addictions, financial capacity

 

– Life event – deceased or bereavement

 

– Fraud – coercion

 

– Physical – accessibility, physical disability, physical health

 

In summary

 

Vulnerability is complex by nature but it’s a challenge that must be addressed. There’s more pressure than ever with continued macro-economic turbulence and regulatory pressure on businesses to take greater accountability in treating vulnerable customers fairly, inclusively, and avoiding causing them foreseeable harm.

 

The FCA defines four drivers of vulnerability as; Health; Life Events; Resilience; and Capability. Each of these categories can be identified and detected with financial, non-financial or a combination of indicators. The stage of vulnerability that a consumer is experiencing can be mapped to three stages of the vulnerability spectrum: signs of vulnerability, financial stress indicators and financial difficulties.

 

For each stage TransUnion can support businesses with key data indicators, allowing them to leverage these insights to identify consumers showing signs of financial stress, and take action to help prevent them from encountering further harm.

 

Read the full article here.

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