PIMFA
Useful tools for identifying vulnerability
There are many tools available for identifying vulnerability including:
The TEXAS Drill
This can help all frontline staff manage disclosures effectively which is a key part of creating an organisation where customers are confident to disclose. It can be used as a training tool for managing initial conversations.
The IDEA Protocol
This can be used for specialist staff to help structure and manage in-depth conversations, ask the right questions, and identify relevant information.
The CARERS Drill
This was developed to assist with handling disclosures from carers to ensure that helpful information is not lost due to staff concerns about data protection.
The BRUCE Drill
This has been designed to remind staff of the key aspects of decision-making and can be used when the customer has mental capacity limitations.
Want to know more? Read the FCA Practitioners’ Pack
- THE TEXAS DRILL
The TEXAS Model has become a tool that is issued across the sectors to handle a wide range of vulnerable situations. It helps ensure firms record:
- The most relevant information about the characteristics of vulnerability
- How these characteristics affect support needs, and
- Helping to meet data protection requirements.
- The IDEA Protocol
Impact
Staff should ask what the mental health problem either stops the customer from doing in relation to their financial situation or makes it harder for them to do. This will help provide insight into both the severity of the condition and its consequences.
“What are you finding hard?”
“ What has been the impact on your day-to-day living?”
Duration
Staff should discuss how long the customer has been living with the reported mental health problem, as the duration of different conditions will vary. This can inform decisions about the amount of time someone needs to be given to retake control of their situation.
“How long have you been experiencing this?”
Episodes
Some people will experience more than one episode of poor mental health in their lives.
“Does this happen often?”
Assistance
Firms should consider whether the customer has been able to get any care, help, support or treatment for their condition. This may help in relation to collecting medical evidence.
“Are you receiving any support/assistance?
Throughout, firms should consider not only the commercial outcomes they wish to achieve but also the steps that would bring about better customer outcomes for their health and financial well-being.
- The CARERS Drill
Check for authority
If the carer can supply evidence of their authority to act on the customer’s behalf, a more detailed discussion can be arranged once this is received – if the carer cannot supply this evidence or needs to share information about the customer now, the following steps should be taken:
Avoid
Avoid discussing any account details, making sure to explain to the carer why this isn’t possible.
Reassure
Let the carer know that their concerns can still, however, be recorded as observations (unverified) on the customer’s account, and these can be looked into.
Explain
Explain that their observations will need to be shared with the customer, colleagues, and potentially any clients. Carers will need to give their consent for this.
Record
Record the carer’s observations, listening carefully and ensuring:
- You have checked why the customer is unable to speak directly about these issues (is there, for example, a communication issue?)
- You are clear how the customer’s mental health problem affects their ability.
- You have confirmed with the carer what information has been recorded, and how long these unverified observations will be held on file while they are being checked.
Summarise
Summarise the available next steps, which might include: you (or a colleague) speaking with the customer concerned to establish if there is a problem, including checking the unverified observations made by the carer; the carer discussing with the customer a potential mandate to act on their behalf; and the carer and customer working together to collect supporting medical evidence.
- The Bruce Drill
Behaviour
Monitor a customer’s behaviour and speech – these may suggest a customer is struggling with decision-making.
Remembering
Is the customer exhibiting any problems with their memory or recall?
Possible questions:
“Would it be helpful if I went over that again?”
“Would it be helpful if I put that in writing?”
“Is there someone that usually helps you with your finances?“
Understanding
Does the customer grasp or understand the information given to them?
Possible questions:
“Do you want to tell me what you’ve understood so far and I can fill in the gaps?”
“Would it help if I explained that again?”
“Is there someone that usually helps you with your finances?”
Communication
Can the customer share and communicate their thoughts, questions, and decisions about what they want to do?
Possible questions:
“Is there another way you’d like us to communicate with you?”
“Is there another time when it would be better to have this conversation?”
“Take your time.”
Evaluation
Can the customer ‘weigh-up’ the different options open to them?
Possible questions:
“Would it be helpful to go through each option again?”
“Do you have someone you normally talk these things through with?”
This guide provides support for firms to identify, support and achieve good outcomes for vulnerable customers.
