Vulnerable customers

With as many as nearly one in two people in the UK showing characteristics of vulnerability¹, it’s vital you know how to identify vulnerable customers to ensure they’re not disadvantaged in any way. Vulnerability can arise for any number of reasons and vulnerable customers are often at greater risk of poor outcomes when it comes to dealing with their finances. To help you spot customers who are potentially at risk, we’ve put together this section to show you some of the signs to look out for and how we can support them.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer² 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.”

The FCA has issued guidance about how regulated firms can support vulnerable customers which says: "All customers are at risk of becoming vulnerable, but this risk is increased by having characteristics of vulnerability. These could be poor health, such as cognitive impairment; life events, such as new caring responsibilities; low resilience to cope with financial or emotional shocks; and low capability, such as poor literacy or numeracy skills."

What makes a customer vulnerable?

There are lots of circumstances and situations that could mean a customer is identified as being vulnerable. While a vulnerability may not affect a customer’s ability to manage their finances, it could impact their understanding of the implications of carrying out certain transactions.

The FCA’s four key drivers of vulnerability include:

Health

Conditions or illnesses that affect the ability to carry out day-to-day tasks, such as physical disability, severe or long-term illness, hearing or visual impairment, mental health conditions, addiction and a low mental or cognitive ability.

Life events

Such as bereavement, job loss or relationship break down. This can include things such as retirement, income shock, domestic abuse and caring responsibilities.

Resilience

Low ability to withstand financial or emotional shocks, such as inadequate or erratic income, over-indebtedness, low savings and low emotional resilience.

Capability

Low knowledge of financial matters, low confidence in managing money (financial capability) or low capability in other relevant areas, such as literacy or digital skills.

How do I identify vulnerable customers?

When speaking with a customer face-to-face or on the phone they may:

Seem confused or unable to understand you
Struggle to answer basic questions
Appear to be intoxicated or under the influence of alcohol
Repeatedly ask the same or similar questions, or ask unrelated questions
Appear agitated or upset

When communicating with a customer by letter or email they may:

Write in a disjointed manner, or a change from their usual writing style (always check their previous correspondence)
Make unusual or unexpected decisions

State that they had assistance from someone else with basic decision making
Say that they are confused and don’t understand
Be unable to recall information previously provided

How does OSB Group support vulnerable customers?

As an FCA regulated lender, we’re committed to ensuring vulnerable customers receive consistently fair treatment so they experience outcomes as good as those received by other customers.

Here are just some of ways we can support your vulnerable customers:

We treat every customer as an individual and will do everything we can to understand and support their needs.
We promise to remain open and approachable, and to listen and respond to our customers with sensitivity and respect.
Our colleagues have received specialist training to ensure customers are treated with sensitivity, respect and compassion.

Our systems and internal processes are flexible to ensure customers’ individual needs are considered in an appropriate and sensitive manner.
Our policies, products and services are regularly reviewed and updated, to help improve the overall customer experience.
Our communications will remain clear, accessible and easy to understand.

How do I let you know about vulnerable customers?

If you believe a customer may be vulnerable, it’s important you let us know as soon as possible. Don’t be afraid to tell us. Just because a customer has a vulnerability doesn’t mean we’ll automatically turn them down and it certainly won’t have any bearing on our final decision.

Whatever their support needs, our defined and robust approach ensures they’ll be treated fairly, but we can only start putting the necessary measures in place to deliver a satisfactory outcome for everyone involved – your customer, you and us – if you tell us about their specific needs.

You will need to ensure you have either obtained the customer’s consent to share their vulnerability information with us or that you have an alternative lawful basis under data protection law for doing so. When sharing vulnerability information with us, please ensure you have told the customer you will share the information with us and confirm to us the lawful basis you are relying on.

If you’re dealing with a vulnerable customer, or are concerned they may have vulnerabilities, you can contact us in the following ways: