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Legal Collections – Customer vulnerability… can WE really regulate it?

September 14, 2015
Debt Collection

There were a plethora of articles published as a result of the publishing of the FCA’s “occasional paper 8” which explored the progress creditors have made so far in adapting positive changes in process and activities when identifying and dealing with vulnerable customers and mental health issues. Indeed there is a noticeable improvement since the FCA paper “Consumer Credit and Consumers in Vulnerable Circumstances” was published and this is all to the good. However, vulnerable customers and the treatment of feature high on all regulator agendas not just the FCA. The fact is this paper looked at understanding what a vulnerable customer looks like and how they got there.

The FCA found:

  • One in seven adults has literacy skills that are expected of a child aged 11 or below;
  • Just under half of UK adults have a numeracy attainment age of 11 or below;
  • Almost half of adults do not have enough savings to cover an unexpected bill of £300;
  • Over 1.4m people in the UK are aged 85 or over. The number of people over 85 in the UK is predicted to double in the next 20 years and nearly treble in the next 30 years;
  • In any given year, one in four adults will experience at least one mental disorder; and
  • 16% of working age adults has a disability.

The FCA have a vested interest in ensuring they have a broad and comprehensive understanding of vulnerability, and to support companies in developing strategies and processes that are not of the ‘one size fits all’ mould. They know it is better to have solid a foundation of understanding that allows companies to develop a 360 degree process tailored to their product, their commitments, their customers, their stakeholders and their staff. Customers can move in and out of vulnerability and a case by case approach will make the customer outcome relevant and appreciated.

The FCA also say: “A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care” 

Put into context, companies must not exacerbate customer’s circumstances by failing to act or re-act appropriately to their situation. To do so will invite penalties and increased supervision from regulators probably astounded that the message has not yet been received and acted upon… I mean come on you have to be from another planet to be unaware of your obligations!

The good news is that the ‘journey’ to a fully embedded and auditable TCF programme has been ongoing for years. Therefore Call Centres all over the country are now likely to have more new and younger staff fully embracing TCF as the norm rather than the old school collectors lamenting the loss of the word debtor, they exist, you know they exist! My experience thus far tells me peer pressure will out and the newbie’s are rocking the phones, feeling better about themselves because they are able to deal morally and compassionately with customers whilst still achieving the objectives they were given on starting….win win!

Therefore I conclude m’lud we can and are regulating TCF and must through be getting better at it everyday as repetition and habit will ensure that ensuring a successful customer outcome becomes a subconscious action rather than a conscious one!

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