Vulnerable Consumer Policy

AIM OF POLICY

EB Wealth’s aim is to treat all customers fairly and to ensure that a client’s needs are taken into account at all times and our practices adapted in the best manner possible to ensure that any vulnerable circumstances identified do not impact the level of service and appropriateness of advice received by the client.  Our aim is that all consumers are able to experience outcomes as good as each other, regardless of their circumstances.

DEFINITION OF VULNERABILITY

Vulnerability occurs in a variety of ways which may be permanent, temporary, or even sporadic, dependent on the nature.   Although individuals may not consider themselves as being ‘vulnerable’, we believe that anyone can find themselves in vulnerable circumstances at any time, which in turn may increase a client’s risk of harm or disadvantage e.g., investing in products they do not fully understand or which may not be suitable for them; making rash decisions; not having access to all relevant information, etc.

The Financial Conduct Authority (FCA) has developed the following definition to guide work in this area:

“A vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

The FCA have also identified the following four key drivers, which show different characteristics of vulnerability (the examples provided below are not considered to be exhaustive), any of which may indicate that a client could be considered vulnerable:

1.       Health

  • Physical disability

  • Severe or long-term illness

  • Hearing or visual impairment

  • Mental health condition or disability

  • Addiction

  • Low mental capacity or cognitive disability

 2.       Life events

  • Retirement

  • Bereavement

  • Income Shock (e.g., coming into an unusually large amount of money or loss of income)

  • Relationship breakdown

  • Domestic abuse (including economic control)

  • Caring responsibilities

  • Other circumstances that affect people’s experience of financial services e.g., leaving care, migration or seeking asylum, human trafficking or modern slavery, convictions

 3.       Resilience

  • Inadequate (outgoings exceed income) or erratic income

  • Over-indebtedness

  • Low savings

  • Low emotional resilience

4.       Capability

  • Low knowledge or confidence in managing finances

  • Poor literacy or numeracy skills

  • Poor English language skills

  • Poor or non-existent digital skills

  • Learning difficulties

  • No or low access to help or support

CONSUMERS IN VULNERABLE CIRCUMSTANCES

Where clients find themselves in vulnerable circumstances, this does not automatically mean they will be considered vulnerable, but they may be more likely to have additional or different needs which, if not met, could limit their ability to make decisions or to represent their own interests. Therefore, the level of care that is appropriate for these consumers may be different from that for others e.g., they may require another individual to attend all meetings with them to ensure they fully understand any recommendations.

We recognise that vulnerability may not be simply due to the situation of an individual but caused or aggravated by the actions or processes of others. We also recognise that a client’s circumstances may change over time. 

IDENTIFYING CLIENTS IN VULNERABLE CIRCUMSTANCES

Our processes ensure that we are constantly evaluating and assessing our clients’ circumstances. 

All clients are required to complete an online Fact Find together with our advisers as part of our standard procedures, which enables us to assess a client’s situation.  The Fact Find also contains a specific field in relation to Vulnerable Circumstances such that a clear record is retained for all clients as to whether we consider them to be in vulnerable circumstances or not and any action / additional care taken to ensure that the risks and features of any recommendation are fully understood.   A client’s circumstances – and any vulnerabilities – are revisited in depth at least annually during a client’s annual review, as well as at the outset of engaging EBW for any other individual piece of business throughout the year, at which time our advisers will go through the full Fact Find with them and update accordingly.  Clients are also specifically requested to notify us of any changes to their circumstances at different points throughout the year e.g., when approving our portfolio updates (scheduled quarterly) or approving a recommendation to invest monies from within their portfolios into a structured product.

All clients have access to their full Fact Finds.  The information in the Vulnerable Circumstances field is included in any suitability report that is prepared for the client: all reports contain a section on Vulnerability, whether a client is considered to be in vulnerable circumstances or not.

Where a client is considered to be in vulnerable circumstances, a note is also made on our database in the form of a banner on the client’s landing page.  This enables any member of staff dealing with the client to immediately recognise any vulnerabilities and act accordingly.

OUR TREATMENT OF CLIENTS IN VULNERABLE CIRCUMSTANCES

We aim to treat any client according to their vulnerable circumstances and will not discriminate against such clients: we are confident we do not offer a less substantial service.  We give all clients - not just those in vulnerable circumstances - the opportunity to have a trusted friend, relative or other third party present at any of our client meetings to assist them in making decisions.  This offer is recorded on a client’s Fact Find, as well as the identification of any nominated third-party, so that it is clear to a third party viewing the file that the client has been afforded a high level of protection in relation to providing recommendations that aim to deliver a good outcome.

Most of the vulnerable circumstances that we identify amongst our client base are in relation to health or life events, including clients who feel less confident in making financial decisions as they get older.

In recognition of this, we are proactive in recommending to clients to think about who they may like to consider nominating to attend meetings with them at an early stage.  Where we feel appropriate to do so, we also go a step further and encourage our clients to provide ourselves with written authority to discuss all matters with both themselves and a trusted friend / relative, who may also be able to make decisions on their behalf.  We also encourage our clients to put a more formal Power of Attorney in place.

As with other clients, we will not provide a recommendation report that has new information in it without thoroughly talking through all the salient points.  For those clients with a low level of financial knowledge, we will confirm with the client that they have understood the recommendations being proposed and the reasons why.  The reports we produce are written in a style that we believe to be clear and uncomplicated and the products that we recommend are not considered to be high risk / complex.  We also provide all the supporting documentation from the provider that can be read in a client’s own time. 

In addition, it is our standard practice that we pre-populate application forms for our clients for their review.  This helps ensure that there is no confusion in what information is being requested and makes the process more streamlined and less stressful for the client.

Where a client is not mobile, we can conduct most business over the phone / via video call and we can arrange to visit the client (within a reasonable distance from the office) if a face-to-face meeting is required.  Although our office is on the second floor, we ensure we book any face-to-face meetings with clients with mobility issues in the meeting room on the ground floor.

Where a client does not consider themselves computer literate, we are able to provide any documents to them by post and are able to provide in a larger font if required.  Our website is also compatible with Immersive Reader tools.

The above mitigating actions are not exhaustive but based predominantly on our most common scenarios: our actions will be adapted based on any client’s personal circumstances. 

STAFF TRAINING

All of our staff are trained on our Vulnerable Consumer policy.

When clients call, staff are able to look them up on our database and see immediately if there are any comments in regards to their vulnerable circumstances and act accordingly.