Only for use by mortgage intermediaries.
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Guidance for intermediaries
Customers in Vulnerable Situations
Who are clients in vulnerable situations?
Clients in vulnerable situations are defined by the FCA 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.
How do I identify a client in a vulnerable situation?
It is important that you look for indicators, probe and ask about vulnerabilities that might be relevant to ensure we give the client the most appropriate support available.
There are 3 key ways you may identify that a client is experiencing a vulnerable situation which are outlined below:
- Client disclosure.
- Red flags which you need to look for.
- Client support needs which you need to be aware of.
Client Disclosure
Clients may tell you about their vulnerable situation. When this happens, you can use the TEXAS framework below:
T - Thank
Thank the customer for giving you the information.
E - Explain
Explain they will need to let us know. Reassure the customer that all information is treated confidentially and only used internally.
X - EXplicit consent
Ask if the customer is happy for you to record the information and get verbal consent. Only capture and relay vulnerable information with consent.
A - Ask
Ask questions to understand:
- Impact: What is the impact on you and your finances?
- Duration: How long has it been going on for?
- Episodes: Has it happened before? Could it happen again?
- Assistance: Do you have support (family, friends, charities etc)
S - Signpost
- Signpost and ask them to speak with us.
- Make customers aware of the 'Here to support you' page on our website, and the charities and support organisations mentioned there.
Indicators
These are things you see or hear that could indicate an underlying vulnerable situation. For example:
- Client makes reference to contact with the medical or social care sector, life events or cognitive difficulties.
- Client makes reference to things we have ‘done to them’ or ‘not done for them’.
- They may ask to bring a trusted person with them for support.
If you identify an indicator, don’t walk past it. The TEXAS framework (in step 1) can help you to sensitively probe the vulnerability and identify how we can best help the client.
Identifying the support the client needs
A vulnerable situation can affect a client’s capacity to interact with us. The BRUCE framework helps to identify what support the client needs:
B - Behaviours & Talk
Look for indicators of limitations in the customer's behaviours and speech.
R - Remembering
Is the customer experiencing problems with their memory or recall?
U - Understanding
Does the customer understand the informaton they're being given?
C - Communicating
Can the customer communicate their thoughts, questions and decisions about what they want to do?
E - Evaluating
Can the customer 'weigh-up' the different options open to them?
How can they let you know about support they need?
Clients can discuss their situation with their Personal Banker at any time.
If the client is new to Coutts they need to contact us once their mortgage has completed.
Accessibility services to help with clients' day to day banking
We're always looking to improve our services to support our clients with their day-to-day banking. You can find a range of information and details of the different ways we can help on our “Here to Support You” page.