Historically, brokers have used the note fields on client screens to record what would now be regarded as vulnerabilities. They may also have made diary or event notes to record the information. It is also possible to have “sticky notes” turned on and use those, which is probably the worst way to record them!
A while ago, Open GI introduced the Consumer Support button, which is a very useful tool that can help turn vulnerable customer procedures into something that actually works in day-to-day customer interactions.
The FCA’s expectations are clear. Firms should be able to identify customers in vulnerable circumstances, understand their needs and act to meet those needs. The FCA also says that unless firms capture information about customer needs, it is highly unlikely that they will be able to meet the needs of all their customers.
That is exactly where Open GI’s Consumer Support functionality can help.
Open GI describes the functionality as a way of capturing consumer support requirements in line with the FCA Consumer Duty, including details of support needs discussed with the customer and any action taken.
Importantly, the information is held in a structured format. This makes it much easier to review and report on, where required, than information recorded in note fields, event frames and, certainly, “sticky notes”.
Rather than simply adding a note somewhere on the client file saying “vulnerable customer”, teams can create a Consumer Support record containing information such as:
the relevant category of vulnerability or support need;
the adjustments the customer requires;
whether the need is short-term;
a review date;
the source of the information; and
the relevant policy reference.
There are also fields for recording whether the customer has agreed to the information being captured and shared.
A good example shown within the Open GI guidance is a customer requiring Braille documents. This is much more useful operationally than simply recording that the customer has a visual impairment. The important information for the person dealing with the customer is what they need us to do differently.
The FCA does not want vulnerability policies simply sitting on a shelf, in a folder, on a shared drive or on a page in SharePoint. It expects firms to design and deliver support that meets customers’ needs, including those with characteristics of vulnerability, and to monitor whether those customers are receiving good outcomes.
The FCA has also identified as good practice firms improving the way they capture and record customer vulnerabilities and support requirements, including the use of flags to identify customers requiring alternative document formats.
Using the Consumer Support button consistently therefore provides brokers with a practical way of demonstrating that vulnerability is being recognised and acted upon.
Really, the key is how the system is used. Teams should avoid unnecessarily detailed descriptions of a customer’s medical condition or personal circumstances. Instead, wherever possible, they should record the information colleagues genuinely need to provide appropriate support.
For example: “Customer requires correspondence in large print” is generally much more useful than a lengthy description of the medical condition causing their sight difficulties.
Open GI also allows records to be updated, records when adjustments have been made and can retain an audit history of changes. Used properly, the Consumer Support button gives Open GI brokers a simple way to move from:
“We have a vulnerable customer policy” to “We can show how we identify customer needs, record them and make sure we respond to them.” And that is much closer to what Consumer Duty is actually about.
If you haven’t moved your vulnerability data from the various places you currently have it into the Consumer Support area, it is worth reviewing whether this functionality could provide a more consistent and useful way of recording and managing that information.
Don’t just record the vulnerability. Record the support
