Vulnerability: A guide for debt collection

A 21-step guide to help customer-facing staff understand and deal with vulnerable consumers, created by Chris Fitch.

Vulnerability: A guide for debt collection

Vulnerability is not a new concept for consumer credit firms. It remains a very complex area where the natural desire to help customers meets the operational challenge of identifying who needs the help, and what that should be.

As far back as 2004 regulators were including vulnerability in guidance documents for the credit industry. Unhelpfully, these gave little indication of what vulnerability meant, or how to deal with it. Consequently, credit firms were largely on their own when addressing these issues.

More recently, the Financial Conduct Authority published an Occasional Paper in 2015 which re-ignited the debate about what vulnerability is, and ‘what good looks like’ when assisting customers in vulnerable circumstances.

In response, the Finance & Leasing Association (FLA) and The UK Cards Association worked with the University of Bristol’s Personal Finance Research Centre (PFRC) to develop research that would help their members identify and support customers in vulnerable circumstances.

The PFRC collated the experience of 1,600 collections staff working at 27 UK lenders and debt collection firms, to produce Vulnerability: a guide for debt collection.

It looks at the full range of life events that can leave customers less able to conduct their affairs effectively, and is intended to provide practical, commercially-viable approaches which could be adapted for sectors as diverse as the credit industry, utilities, telecoms, retail, and government.

Organised into 21 Steps, the first section describes a general approach to identifying vulnerability and how to broach the subject in conversation with customers. It also provides guidance on correctly handling customer disclosures (including in the complex area of carer disclosures) and practical advice on ending conversations in a way which helpfully summarises what has been agreed.

The next section looks at a series of specific vulnerabilities, such as serious or terminal illness, bereavement, addictions, and mental health issues including the risk of suicide, and suggests a tailored approach in each case which will help staff deal with these potentially challenging situations.
The final section provides guidance on developing training programmes and working with partner agencies, and contains 21 case studies which illustrate the difference that appropriate handling can make to a customer in need of a little extra support.

In essence, the 21 Steps will help customer-facing staff to match their natural instinct to help with the right approach for specific situations. The guide’s recommendations are backed by evidence and illustrated with case studies that will also help firms to oversee this process. They will also provide a great way for firms to benchmark their performance in this important area.