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How do you adapt your communications to meet the needs of customers with characteristics of vulnerability , and how do you know these adaptions are effective ?
Consumers with a vulnerability may not be immediately obvious , we have commentis to aid you with this . Advisers should talk through the key features of the document , allowing those with a low level of financial sophistication to ask questions and advisers to take steps to confirm the client understanding . SimplyBiz have recently published on the operating centre guidance on ‘ Read aloud ’ functionality for electronic documents whilst there are many other adjustments to support the needs of a vulnerable customers that can be made , e . g . offering family / friend meetings or facilitating contact through communication channels that suit the client . Any steps taken should mitigate harm and empower the customer to engage in the advice process , rather than your firm simply recording the vulnerability on file .
What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability ? What data , MI and customer feedback is being used to support this assessment ?
The firm should have an up-to-date and personalised vulnerable person ’ s policy which is kept under review . The VP Policy sets out how to maintain records and keep outcomes under review . However , meeting the needs of potentially vulnerable customers goes beyond an upto date Vulnerable Persons Policy . The adaptations that the firm makes to its advice process to support the needs of a vulnerable customers should be recorded with these steps maintained on file for future reference . Client feedback is again essential as to whether the needs of the clients and fair value is being met . Internally , there should be ongoing discussion around the issue of vulnerability , possibly making use of third-party support to educate staff .
How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support ?
Arguably file reviews are the best way to ensure that advisers are following the advice process and that client files are of an acceptable standard . Each firm should have a file review process where file checks are carried out in line with the firm ’ s Training and Competence Plan . Where a file review results in an unclear or unsuitable outcome , the firm should take steps to address this both with the affected client and with the adviser . This is then recorded and considered in respect of the advisers T & C Plan and FIT assessment .
File review support is available from our Advice Quality Team , for further details please contact aqt @ compliancefirst . co . uk .
Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the duty ?
The three Cross Cutting rules and four Consumer Duty outcomes should be actively engaged upon and at the centre of the firm ’ s ethos with the Consumer Duty fully implemented and adopted with a top-down approach from management . The firm could regularly hold staff meetings to discuss the Consumer Duty and its impact and expectations with annual reviews of Fair Value reported to management . This extends to altering service for your firm , for example if a client is having their fee waivered senior management sign off should be in place for discounting of charges .
Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place ?
There are many risks within a mortgage firm to not delivering good client outcomes and it is management responsibility to ensure due diligence is undertaken on an initial and continuing basis so as the mortgage advice process for the firm and the cheapest suitable mortgage rule is followed . This due diligence will extend to many aspects from research tools to your products / lender knowledge . This should be carried out on an initial and continuing basis with results reviewed and recorded . This involves periodically reviewing products sold that may no longer represent good value for example where insurance or protection terms become more competitive . Where different services are offered such as second charge or lifetime mortgages it is fair that charges reflect the complexity and demands of the service but the price the consumer pays should still be reflected in the value they receive .
Further support in managing your Consumer Duty responsibilities is available .
If would like further information regarding technology support such as the Comentis vulnerability assessment tool or VouchedFor client feedback solution or regulatory assistance with file reviews , training and competence support or to arrange an appointment with one of our Compliance Consultants to review your Consumer Duty progress , please contact the Adviser Services Team on 01484 443 445 or via email at adviserservices @ simplybiz . co . uk .