Our process for dealing with potentially vulnerable customers

A person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process, or cannot communicate their decision.

A person with mental health problems who is in debt is particularly vulnerable due to their (potential):

Assessing a person’s mental health is complex but needs to be recognised in early contact and addressed appropriately. If we believe a person may be vulnerable, we will ask 3 key questions:

  1. Does your mental health affect your financial situations?
  2. Does it affect your ability to deal with or communicate with us?
  3. Does anyone help you to manage your finances such as a family member?

Signs we look out for when identifying vulnerability in customers:                                                     

Steps we take if we believe a customer may be vulnerable:                                                                                               

Prior to forming the contract:         

Post Contract:

If we identify a customer who may be in need of specialist advice which we are unable to offer:

Sources of guidance we refer to:

Equality Act 2010

Mental Capacity Act 2005

CONC 2.10 Contact with customers

Mental Capacity Guidance

Irresponsible Lending Guidance

MALG Consumers with mental health problems & debt

MALG 12 steps to treating vulnerable consumers fairly

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