Vulnerable customers
Identifying a customer with a vulnerability who may require additional support
We know you take care of all your clients, but some need extra care for a variety of reasons. These include customers:
· with vulnerabilities
· who may have been subject to financial crime, such as a scam in the past or involved in high-risk activities
· who are high-risk and you’ve already carried out enhanced due diligence.
We want to be able to offer these customers the additional support they may need as they go through the application process for their lifetime mortgage. We’ll also support them after their application if they need it.
Types of vulnerabilities where we can offer additional support
When you submit an application online, please tell us about any vulnerabilities your clients have and any additional support they may need.
To help you do this, we’ve put together a list of vulnerabilities and another list of the types of additional support we can offer.
If you identify a customer with one or more of these listed vulnerabilities or who needs extra support, please let us know. You can do this by emailing us at LPEQREN@aviva.com to choose their specific vulnerability and/ or confirm the additional support they need from the lists below.
Here is the list of vulnerabilities together with some examples:
· Health – severe or long-term illness
Example: a customer has fibromyalgia and suffers with fibro fogs so telephone conversations should be followed up with email confirmation so the customer can revisit what has been discussed
· Health – hearing impairment
Example: a customer is deaf or hard of hearing and can only communicate by email or a British Sign Language interpreter
· Health – visual impairment
Example: a customer is partially sighted, so all documentation should be in large print
· Health – mental health condition or disability
Example: a customer has anxiety, particularly when communicating by telephone, so we should use alternative communication channels
· Health – speech impairment
Example: if a customer struggles to communicate with us by telephone, we can set their preferred method of communication as email
· Health – memory loss
Example: if a customer suffers with their memory due to age or a health issue, we could liaise with a person holding Power of Attorney
· Health – other
To be used for any other health issues which don’t fall under one of the categories above
· Life event – bereavement
This could have a short- or long-term impact on the customer both financially and emotionally. We can support the customer by adding notes to not discuss the passing of an individual
· Life event – change of how customer self-identifies
Example: if a customer has transitioned, we can add this information to the customer’s profile to prevent Aviva colleagues questioning or challenging the identity of the caller
· Life event – money worries
Example: if a customer has been impacted by the cost of living
· Life event – other circumstances
Example: a customer has carer responsibilities and can only talk on the telephone during specific hours, otherwise we should use alternative communication channels, such as email or post
· Capability – knowledge or confidence in managing finances
Example: if a customer requires additional support to help with their understanding, such as dealing with a person holding Power of Attorney or a Letter of Authority
· Capability – literacy
Example: if a customer requires additional support to help with their understanding, such as dealing with a person holding a Power of Attorney or a Letter of Authority
· Capability – numeracy
Example: if a customer requires additional support to help with their understanding, such as dealing with a person holding Power of Attorney or a Letter of Authority
· Capability – English language
Example: if a customer requires additional support such as a translator or to for a handler to speak clearly and slowly when communicating over the telephone
· Capability – digital
Example: if a customer cannot use digital ways to transact, we can use alternative methods and can flag as ‘do not recommend digital journeys’
· Capability – learning difficulties
Example: if a customer requires additional support to help with their understanding, such as dealing with a person holding Power of Attorney or a Letter of Authority
· Capability – no or low access to help or support
Example: we could signpost a customer to further support from organisations and/or charities that could support them with their specific need, whether that is financial or wellbeing support
· Capability – other
To be used for any other capability issues which do not fall under one of the categories above
· Safeguarding - victim of a financial scam
Example: a customer has been the subject of a scam/fraud and requires additional security around transactions
Additional support available to your clients
We can offer:
· slow-paced communication
· offline communication only
· electronic communication only
· written communication only
· liaison with a person holding Power or Attorney or a Letter of Authority
· phone calls between certain times
Why are we asking you to identify additional support needs?
If we know a customer has a specific vulnerability or needs additional support, we can tailor the service we offer to take their personal circumstances into account and make the process easier for them.
The FCA expects us to capture information on vulnerable customers throughout their application journey, but we do rely on you as their adviser to help us with this.
That said, please only disclose information to us that will help us serve your customer better.
We should not hold information about a client if we are unable to provide additional support.
Please make sure you check with your customer that they are happy for you to pass this information on to us. We’d ask you to confirm they have given their consent by adding this statement to your email to LPEQREN@aviva.com:
Where I have disclosed my customer’s vulnerabilities and/or additional support needs, I have done so with the customer’s consent.
It takes Aviva and you working together to go a step further for your vulnerable clients.
With your support, we can give your clients a smooth and satisfying experience through their lifetime mortgage application and onwards as we service their policy.