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Addressing customer vulnerability

The question of how best to support vulnerable customers is an issue of continuing importance in all sectors, but none more so than the long term savings industry. Retirement can be complex for everyone and recent changes to pensions carries risks for all customers, not least the risk of running out of money, as well as the ongoing risk of fraud and scams.

Part of the challenge for industry and policy-makers in this market is to better understand the customer circumstances that create sufficient risk or vulnerability to require additional support. Circumstances that might categorise someone as vulnerable can be temporary or sporadic states. Customers may not know they are vulnerable or be forthcoming in disclosing what can be very personal information, making it very difficult to identify that someone is vulnerable and to determine the appropriate response.

Therefore, the ABI has produced a new industry guide for providers of long term savings, which sets out principles, good practice and case studies to help providers understand how they can better identify and support vulnerable customers in retirement, both at the point of purchase and throughout the life of the product.

Its objective is to act as reference point to help firms improve their own processes for dealing with vulnerability, by learning from their peers and other sectors about what works well when dealing with a vulnerable customer base. It also aims to create some commonality within the industry in how customers are treated, as it may be the case that individuals are customers of more than one provider. 

Alongside the guide, the ABI’s long term savings members are making three commitments to ensure the progress made within the industry thus far continues:

  1. Firms will implement a vulnerability policy or strategy, if not already present, by January 2018. If one is already in place, firms will review and ensure their internal policies are fit for purpose based on the principles of this guide.
  2. Firms commit to providing regular training to all relevant staff and will continue to raise awareness of vulnerability with colleagues across the business.
  3. Firms continue to share examples of good practice through the ABI, to ensure the industry and its customers benefit from high levels of support, and therefore the guide will be kept continually under review. 

Take a look at our vulnerability guide.

  • Case study 1: Money Advice Trust Traffic Light System

    The Money Advice Trust suggests categorising vulnerability within a Traffic Light system*:

    Green Light: Potentially Vulnerable

    If a customer is currently able to manage their finances, make informed decisions, and is not at risk of detriment due to their situation, then they are neither vulnerable nor particularly vulnerable. Instead, they remain as potentially vulnerable. However, in future, this could change.

    Customers could, for example, develop an unexpected health condition which affects their ability to earn money (an individual factor) or experience an unwelcome change in their wider circumstances (such as the need to provide regular care to a family member). While the customer may be fine at present, things can change.

    Amber Light: Vulnerable

    These are customers who are currently in a situation which means they are more likely to experience harm, loss, or disadvantage than other customers. These customers will hopefully be identified as being in a vulnerable situation by a frontline member of staff or adviser, and will also hopefully receive help and assistance to avoid detriment to them. The firm’s aim here should be to return the customer back to the potentially vulnerable category (where possible), although this may take time.

    Red: Particularly Vulnerable

    These are customers who are currently at a greatly heightened risk of experiencing detriment compared to the majority of vulnerable customers. This detriment could also be far more serious in terms of its negative impact on the customer’s situation, and could be far more imminent. These customers need to be quickly identified by staff or advisers, and action needs to be swift and effective to avoid significant harm. 

    *Note that the wording has been adapted to suit the long term savings market.
  • Case study 2: Just’s techniques for identifying customers via telephony

    There are many techniques available to frontline staff to assist them with the identification of potentially vulnerable customers if not disclosed upfront. Techniques such as discussing family background and a previous career can help assess recollection, as do questions about current affairs and historic events. Recording the answers in the clients own words and reviewing them at subsequent meetings will help test this over time.

  • Case study 3: IDEA drill (Royal College of Psychiatrists/Money Advice Trust)


    Staff should ask what the mental health problem stops or makes it hard for the customer to do in relation to their financial situation.

    This helps to provide insight into both the severity of the condition and its consequences.


    Staff should discuss how long the customer has been living with the reported mental health problem, as the duration of different conditions will vary.

    This can inform decisions about the amount of time someone needs to be given to retake control of their decisions.


    Some people will experience more than one episode of poor mental health in their lives.

    Firms will need to take such fluctuating conditions into account in their decision-making.


    Firms should consider whether the customer has been able to get any care, help, support or treatment for their condition.

    This may help in relation to collecting medical evidence.

    Throughout, firms should keep in mind not only the commercial outcomes they wish to achieve, but also the steps that would bring about better customer outcomes for their health and financial wellbeing.


    *Note that the wording has been adapted to suit the long term savings market.
  • Case study 4: The BLAKE protocol – how to support customers who may be suicidal

    Breathe (to focus) – it can be scary to hear something like this, so take a moment to simply breathe and focus your thoughts. You can do this by acknowledging what the customer has said: “I’m so sorry to hear you feel that way. How can we help?”

    Listen (to understand) – we always take what the customer has shared seriously, but we also always listen carefully so we can assess the imminent risk of harm. Listen to the customer using verbal nods and recapping key information to show your understanding.

    Ask (to discover) – listening is important, but where gaps continue to exist in your understanding about the current situation, you should ask questions to fill these. Example questions could include: “What has led to these feelings?” or “Have you spoken to anyone about how you are feeling?”

    Keep safe (from harm) – based on your understanding of the situation, and also your organisation’s policy, the emergency services should be contacted if the customer is at imminent risk of harm. During this, you may need to stay on the line to keep talking with the customer. Reassure the customer that your primary concern is their safety, and that any financial difficulty can be dealt with later. “I’m worried about what you’ve told me – what can we do to keep you safe?”

    End (with summary) – once customer safety has been addressed, if it is possible to do so, staff should summarise what has been discussed and agreed, so that the call can end (and any data-recording can begin). “We’ve been talking for a while, but before we finish let me summarise what we agreed and what will happen next...”

  • Case study 5: How LV= dealt with an insistent vulnerable customer

    Our Customer Experience Team became concerned about a pension scheme member who repeatedly contacted us to request a lump sum payment from his plan which represented a significant proportion of its overall value. This member was clearly unable to understand or action the steps required to withdraw a lump sum, and became distressed that his request hadn’t been followed, despite being talked through the process several times. This member was flagged as vulnerable and one of our Vulnerable Customer Champions was assigned to the case.

    We received a call from a third party who claimed to be advocate and carer for the scheme member. This individual advised the member was suffering mental health issues and that the family were in the process of obtaining Power of Attorney. They requested we not pay any further money from the scheme, as the member was unable to make such decisions at this time. As this information was from an unknown source, we took steps to verify the possibility of a POA via the Office of the Public Guardian, who confirmed no such arrangement was in place.

    Throughout this period the member contacted us several times, continuing to appear distressed and confused about his withdrawal requests. We issued the appropriate documents again, together with a bespoke letter highlighting the risks of accessing the money, and urging the member to contact their financial adviser for support. We also contacted the servicing financial adviser to flag that the member was experiencing difficulty in accessing their money, and asked that they get in touch with him.

    When we received the paperwork back a few days later, the instruction had changed, from a one off lump sum, to an annual income of a much lower amount, which we consider to be a better outcome for the member. We have since also had contact from an independent organisation acting on behalf of vulnerable individuals, who are now working with this member and his family.

  • Case study 6: ABI member’s handling of an insistent customer

    A customer made contact with us seeking to withdraw all of the money from her husband’s pension plan (she had power of attorney). It transpired that her husband was terminally ill in a hospice and she also had been diagnosed with cancer and she wanted the money to clear debts.

    We made clear that the customer would incur significant tax on the withdrawal and advised that she could be eligible to get the money paid out 100% tax-free if the terminal diagnosis was confirmed. The customer was clearly under significant distress (at one point threatened suicide) which the call handler picked up on.

    At one point, it was a three-way conversation between the call agent, the customer, and her husband from the hospice. Taking this into consideration, instead of processing the transaction as requested we reached an agreement with the customer that they would go to the GP with a view to exploring the serious ill health option. The customer has since done this and returned to us.

    As it turns out the GP has diagnosed that the customer’s husband has longer to live than originally thought so she was unable to get the money tax free. This case demonstrates that 

    there was a recognition of the vulnerability of the customer and a drive to get the customer the best possible outcome, whilst taking their situation into account. The customer made their final decision with an awareness of all of possible options.

  • Case study 7: Lessons from the equity release market

    An ABI member who also operates in the equity release market, is a member of the Equity Release Council and therefore adheres to the ERC Statement of Principles (See References). Customers are offered the option to drawdown funds as and when required. The firm changed its procedures to a telephone-based drawdown process as opposed to paper-based or online so they can interact with elderly customers and better assess their capability, understanding and provide support where needed. This firm has also arranged staff to attend safeguarding training offered by the local council.

  • Case study 8: ABI member’s record keeping system

    We have record keeping systems in place which allow staff to record whether a client is vulnerable, holds details regarding the vulnerability or disability they may have and records any previous support given to the client that ensures a more sympathetic and tailored approach. Not only does this prevent the client from making repeated disclosures to different members of staff, it enables the firm to handle the customer’s account more effectively. Should the vulnerability be temporary, the system is easily able to be updated.

  • Case study 9: TEXAS drill (Royal College of Psychiatrists/Money Advice Trust)


    • Thank the customer (what they have told you could be useful for everyone involved). E.g. “Thank you for informing me. This will enable us to deal with your account better.”


    • Explain how the information the customer has given you will be used (this is a legal requirement).

    E.g. “So you are aware, I will now explain how we intend to use this information.”


    • Explicit consent should be obtained (this is a legal requirement).

    E.g. “In order for us to use this information, I will need your verbal permission to do so. Please could you confirm you are happy to proceed?”


    • Ask the customers questions to get key information to help you better understand their circumstances.

    E.g. “Does your mental health problem affect your ability to deal or communicate with us? If so, how?” “Does anyone need to help you manage your finances such as a carer or relative? If so, how? 


    • Signpost or refer to internal and external help where appropriate.
    • Staff should direct customers to a company specialist or third party:

    – A debt advice agency or help with multiple debts – NHS 111 for more help with mental health issues – The Samaritans for customers with suicidal tendencies

  • Case study 10: the BRUCE protocol – how to identify and spot customers with decision-making difficulties

    Behaviour and talk - staff should monitor a customer’s behaviour and talk for indications of difficulties with:

    Remembering – is the customer exhibiting any problems with their memory or recall?

    Understanding – does the customer grasp or understand the information given to them?

    Communicating – can the customer share and communicate their thoughts, questions and decisions about what they want to do?

    Evaluating – can the customer ‘weigh-up’ the different options open to them?

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