The good news is that the understanding of vulnerability is now such that most firms acknowledge that, due to its very nature, any of their clients can find themselves in vulnerable circumstances. However, the challenge remains around issues of timespecific identification, self-disclosure, the meeting of additional needs, and ongoing monitoring.
Looking at the FCA’ s four drivers of potential vulnerability, one that is very clearly linked to ultimate service provision is that of life events.
Health Life events Resilience Capability
Physical disability Caring responsibilities Low or erratic income
Low knowledge or confidence in managing financial matters
Severe or long-term illness
Hearing or visual impairments
Bereavement Over indebtedness Poor literacy or numeracy skills
Relationship breakdown Low emotional resilience Poor or non-existent digital skills
Low mental capacity or cognitive disabilities |
Having non-standard requirements such as ex-offenders, care leavers, refugees |
Lack of support structure |
Learning impairments |
Source: FCA Finalised guidance FG21 / 1: Guidance for firms on the fair treatment of vulnerable customer
Due to the nature of advice, advisers are often well placed to become aware of bereavement, significant changes in income, or divorce, and provide appropriate financial services. However, that’ s not always the case when it comes to one of the biggest drivers of vulnerability- caring responsibilities, especially when the person being cared for is an older adult.
Where this is the case, many unpaid carers, typically the children of the older adult who is the client of the advice firm, often don’ t view themselves as a carer. Alternatively, if they do, they tend to underplay its impact by seeing it as something that is just a part of the ups and downs of family life. They seldom associate what they do as‘ an event driver of vulnerability’. Indeed, polling from a report by organisations involved in Carers Week * shows nearly three quarters of people( 73 %) who currently provide unpaid care, or have provided care in the past, have never identified as, or called themselves, a carer, despite the fact that caring can manifest in observable frustration, stress, and the deterioration of overall wellbeing. This strongly suggests that a significant number of people providing unpaid care may not be receiving information, advice, or support to help them with their caring role.
By the time they are aged 46, half of women have been a carer. men have the same 50:50 chance by age 57- eleven years later.
73 %
of people who are providing or have provided unpaid care do not indentify themselves as a carer.
* https:// www. carersweek. org / media / yqkdkodx / carers-week-report-2023. pdf
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