Vulnerable Client Policy

Overview

The purpose of this policy is to ensure that the operations of TMG (The Mortgage Geezer), trading as Access Financial Services, do not adversely affect vulnerable clients and that where a client is identified as vulnerable, we take appropriate steps to ensure they are treated fairly.

We are committed to:

• Considering the needs of vulnerable clients in the design and delivery of our services
• Equipping staff with the skills and knowledge to recognise and respond to vulnerability
• Enabling clients to disclose their needs and offering support where appropriate
• Being empathetic and treating every client as an individual
• Monitoring outcomes and using management information to improve our approach

What is a Vulnerable Client?

The FCA defines a vulnerable customer 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.

A vulnerable client may be less able to represent their own interests, less able to make informed decisions, or more likely to be subject to detriment. It is important to note that clients may not always think of themselves as vulnerable, and vulnerability can be temporary, sporadic or permanent.

Considering Needs in Service Design

We design our services with the needs of vulnerable clients in mind. This includes:

• Ensuring our processes do not create harmful consequences for vulnerable clients
• Making information and communications clear, understandable and accessible
• Providing flexibility in how clients can interact with us

Types of Vulnerability

The FCA identifies four key drivers of vulnerability. The following table sets out examples under each category:

Other Factors

In addition to the drivers above, we also consider:

• Older clients – who may have additional needs relating to health, mobility or cognitive decline
• Non-standard documents – clients who may require information in alternative formats such as large print, Braille, or audio
• Cost of living pressures – clients experiencing financial hardship due to rising living costs

Training

All staff receive training on vulnerability awareness to ensure they can identify and respond appropriately when dealing with vulnerable clients. This includes:

• Awareness training on identifying signs of vulnerability
• Annual testing and competence assessments
• Ongoing monitoring by the Training & Competence team

Identifying a Vulnerable Client

Vulnerability may be identified at any stage of the client relationship. Our Know Your Client (KYC) process is designed to help identify vulnerability at the outset. Where a client is identified as potentially vulnerable, a Vulnerable Client Assessment form is completed.

Indicators of vulnerability may include:

• Requests to withdraw from a process or sudden changes of mind
• Changes in risk appetite that seem inconsistent
• Difficulty understanding language or terminology used
• Physical signs such as distress, confusion, or unease

Capturing Data

Where vulnerability is identified, this is recorded on our systems in line with data protection requirements. Our Mortgage Magic CRM system is used to record and flag vulnerable clients to ensure continuity of care throughout the advice process.

Dealing with Empathy

When dealing with a potentially vulnerable client, we will consider whether the client has the capacity to make informed decisions. If there is any doubt about capacity, the process should be paused and referred to the Compliance Director for guidance.

External Support

Where appropriate, we will provide clients with details of external organisations that may be able to offer support relevant to their circumstances, such as debt advice charities, mental health support services, or bereavement support.

Monitoring Outcomes

We use management information to monitor outcomes for vulnerable clients and ensure they are not being disadvantaged. This is reviewed at Board Meetings as part of the Consumer Duty agenda. Data sources include:

• Complaints data and root cause analysis
• Vulnerable client assessments completed
• Training and competence records
• File reviews and quality assurance checks
• Client feedback and satisfaction surveys

Policy Review

This policy is reviewed annually by Jeremy Lock, Compliance Director. Any updates are communicated to all staff within five working days of approval.