Vulnerability and Affordability

Given the recent history of the Covid pandemic and the “Cost of Living Crisis” the issues of vulnerability and affordability have never been more in the spotlight for those managing public sector debt recovery matters.

All of our team members receive comprehensive training both when joining the firm and annually on customer vulnerability and affordability issues. The training is aimed at ensuring our team members obtain a clear understanding of what it means to be vulnerable, the types of vulnerability including Communication, Medical and Financial and are provided the tools to be able to clearly identify a person who is vulnerable. Team members are trained how to listen, question, and adopt a close attention to detail approach so that flags, indicators, and risk factors are not missed. The training also explains how team members should, where appropriate, signpost customers for further assistance.

Further as part of our FCA Consumer duty obligations, we are required to consider outcomes and to ensure that particular groups do not face worse outcomes than others. As such this will include an assessment of whether those with identified vulnerabilities achieve worse outcomes than those without. At present we have seen no evidence that this is the case. However, this will be tracked. If we found a trend which suggested there was a disparity of outcome, we would be able to implement measures to mitigate that outcome.

Where we obtain consent to flag the vulnerability our team members are required to add a vulnerability flag on the case file. This allows us to accurately report on cases identified as vulnerable along with the high-level nature of the vulnerability.