Ensuring that consumers are treated fairly is an overarching objective for the FCA. The FCA particularly want to ensure that consumers in vulnerable circumstances are protected – this includes protecting people from over-indebtedness.  The FCA define a vulnerable consumer as ‘someone who, due to their personal circumstances, is especially susceptible to detriment’.

Your sales team needs to be trained on recognising potentially vulnerable persons

There are a number of individual and behavioural factors that increase a consumer’s vulnerability; not least of which is the fact customers have variable levels of knowledge about consumer credit.  As a credit broker you should be able to demonstrate that your sales team take steps to identify potentially vulnerable consumers and that you do not inappropriately sell finance to them.

Retailers should be aware that some consumers may not ask questions about the finance they are being offered because they lack confidence or because they are afraid of being embarrassed.  Retailers have a responsibility to ensure consumers are in full possession of all the facts. This not only benefits consumers but your business too – it could potentially reduce the number of cancelled finance agreements.

Creating a vulnerable persons policy as part of your FCA application

When applying for FCA Authorisation you will need to provide evidence of your vulnerable persons policy. Below is an example policy statement:

At [company name] we realise that sometimes a customer may be vulnerable as a consequence of mental or physical infirmity, age, credulity, learning difficulties, illiteracy and/or if English is not their first language.

Should this situation arise and it becomes obvious that the information we provide to the customer is not being understood then we will ask the customer to seek the involvement of a trusted friend or relative before proceeding. We will then make a new appointment to visit the customer’s home at a time when the trusted friend or relative can be present.


If you need further information about creating or implementing a vulnerable persons policy in your sales team then please contact Head Office on 0845 120 6666.