Helping clients in vulnerable circumstances
Why this matters
Recognising and supporting potentially vulnerable customers is more important than ever. This presents a significant challenge and opportunity for financial advisers.
When it comes to later life lending, our priority is more than meeting regulations it’s about making every interaction clear, empathetic, and accessible. By focusing on clients needs and building trust, we aim to deliver safe, good outcomes that truly support their financial wellbeing.
Things to consider:
The Financial Conduct Authority (FCA) requires advisers to go beyond basic compliance by actively identifying and supporting customers who may be vulnerable. This means demonstrating a clear understanding of vulnerability factors, implementing robust policies, and ensuring that advice is tailored to individual needs. Advisers should document how they assess vulnerability, provide accessible communication options, and take steps to prevent harm, ultimately delivering good outcomes that align with Consumer Duty principles.
Achieving good outcomes for vulnerable clients means more than treating everyone the same. Equality does not always lead to fairness. Firms must actively recognise where individual needs differ and adapt their approach to ensure vulnerable clients receive outcomes that are just as positive as those of other clients. This involves tailoring advice, communication, and support to address specific challenges such as health issues, life events, or financial resilience, while maintaining clarity and empathy throughout the process. By doing so, advisers help clients make informed decisions, reduce risk of harm, and build trust that leads to long-term financial wellbeing.
Many clients may not openly disclose their challenges, and some may not even recognise that they are vulnerable. This can stem from a lack of awareness, reluctance to share personal details, or fear of stigma. As a result, advisers need to be proactive in identifying subtle indicators such as changes in behaviour, communication difficulties, or signs of financial stress to ensure that support is offered before issues escalate.
How we can support you and your customers
Talking to your client and spotting the signs of a vulnerability is key to offering them tailored support.
Here are some examples of how we can assist:
When applying through our online portal, you can share details of your client’s needs. This does not affect the outcome of their application. It simply enables us to tailor our communication and support to better meet their circumstances.
Understanding client vulnerability
Power of Attorney (POA)
Why establish a POA?
Setting up a POA is a proactive and responsible step that offers clarity, security, and control for the future.
1. Proactive planning
Establishing a POA early enables individuals to engage in meaningful conversations with family members about how decisions should be made if they become unable to do so themselves.
2. Peace of mind
Knowing that a trusted person is legally empowered to act on their behalf provides reassurance and emotional security for both the individual and their loved ones.
3. Continued autonomy
Registering a POA does not remove the individual’s ability to manage their own finances or make decisions. They retain control for as long as they have mental capacity.
You may want to share this information with your client or direct them to our customer web page.
POA checklist for new business applications
New applications are accepted under a POA where the customer has been confirmed to have lost mental capacity. This must be confirmed with a GP letter, Consultant or psychiatrist report or a Mental Health professional’s capacity assessment.
Before accepting an Attorney’s instruction:
Accepted POA types
England & Wales
- Enduring Power of Attorney
- Lasting Power of Attorney (Property & Financial Affairs)
Scotland
- Continuing Power of Attorney
- Combined Power of Attorney
Key requirements
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All attorneys must have received UK financial and legal advice.
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Where there is a joint application, a borrower cannot sign the mortgage deed as both owner and attorney. This is not accepted by the Land Registry.
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For POA’s registered after 17 July 2020 we can accept the POA access code to view or download the POA document. For POA’s registered before that date we require the paper version.
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If we cannot electronically verify the attorney’s identity and residency, we will need documents to verify these. See our Customer ID Guide
Our referral partnerships
We collaborate with the Royal Voluntary Service and Step Change to provide dedicated support for clients in vulnerable circumstances. In addition, we maintain a comprehensive toolkit of trusted charities and resources to ensure clients receive the assistance they need.
You can be assured that we will look after your clients when they become our customers and may need additional support.
Lifelong support for your clients
Care Concierge
Our Care Concierge service offers personalised guidance to help clients and their families navigate the complexities of adult and later life care — from understanding options to finding and funding the right support. This service is available to everyone, and your clients can access it whenever they need, ensuring peace of mind at every stage.
Power of Attorney referrals
If you think your client would benefit from having a POA in place, we’ve partnered with Co-op Legal Services to offer a telephone referral service for clients who have a need for a POA. All our customers are eligible for a 10% discount on this service.