What is a Vulnerable Customer?

A vulnerable customer is someone who, due to personal circumstances, is especially susceptible to harm when engaging with financial services. The FCA expects firms to identify, understand, and appropriately support such customers to ensure fair treatment and good outcomes.

For further help and detail on how we can all work together to ensure customers receive all the help they need, please also take a look at the ‘Working together to support our vulnerable customers’ guide put together by Aldermore.

Should you have any questions, please contact the Compliance team who will be happy to help.

Common drivers of vulnerability include

Health – physical or mental illness, disability, addiction.
Life Events – bereavement, job loss, relationship breakdown.
Resilience – low savings, over-indebtedness, financial stress.
Capability – low financial literacy, poor digital skills, language barriers.

Why It Matters

Meeting FCA Consumer Duty and Treating Customers Fairly requirements.
Ensuring decisions are in the best interests of clients.
Building trust and long-term relationships.

The TEXAS Model

The TEXAS model is a structured approach to dealing with disclosures of vulnerability. It helps advisers respond consistently, empathetically, and compliantly.

  • T – Thank | Thank the customer for sharing. Acknowledge their situation and show empathy. Example: “Thank you for letting me know, I appreciate you sharing this with me.”
  • E – Explain – Explain why you need the information and how it will help you provide the right support. Example: “This will help me make sure we give you the right advice and avoid anything that might cause difficulties
  • X – eXplicit Consent – Get clear consent before recording or sharing any sensitive information. Example: “Is it okay if I note this down so we can make sure we take it into account?”
  • A – Ask – Ask about the impact of the vulnerability on their financial situation and preferences. Example: “Would you like us to adapt how we communicate with you, for example, by email instead of phone?”
  • S – Signpost – Offer additional help, either within your firm or to external specialist organisations. Example: “If you’d like, I can point you towards support services that may be able to help further.”

For further help and detail on how we can all work together to ensure customers receive all the help they need, please also take a look at the ‘Working together to support our vulnerable customers’ guide put together by Aldermore.

Should you have any questions, please contact the Compliance team who will be happy to help.

Regards

Alan Baldwin

Director of Compliance & Operations

For any questions or queries regarding this email, please contact Member Support Team: membersupport@connectmortgages.co.uk