Vulnerable customers

How we define a vulnerable customer

Kent Reliance for Intermediaries is committed to treating vulnerable customers fairly, consistently and in a way that considers their individual needs.

We see vulnerable customers as those who may be susceptible to detriment due to their personal circumstances. It’s our belief and understanding that every customer may at some stage be considered vulnerable, and it’s our aim to help ensure all customers consistently receive fair outcomes when dealing with us, and that you as a broker are able to identify the signs of vulnerability when they occur.

How we support vulnerable customers

We recognise the importance of identifying vulnerable customers and ensuring that they receive the appropriate treatment on an ongoing basis.

We encourage our broker partners to talk to us about their customer’s circumstances, so that we engage with them correctly and handle their information, and the information of their customers, in the right way.

Vulnerability should be considered with four key factors in mind:

Physical -A physical impairment may prevent a customer from being able to transact with us in the same manner as others. They may require additional support in any dealings with Kent Reliance for Intermediaries.

Low financial resilience - Limited financial knowledge may mean a customer is unable to manage their finances effectively, engage confidently with lenders, financial service providers and to make informed decisions.

Low financial capability - Lacking the funds and/or financial support required to transact with us due to a change in the customer’s circumstances. They may even be unaware that they are in fact a vulnerable customer.

Impact of life events - External life events such a family bereavement, divorce, illness or redundancies that may affect the customer’s emotional and mental wellbeing.

Our response to vulnerability

Kent Reliance for Intermediaries is fully committed to meeting its regulatory and statutory responsibilities when dealing with vulnerable customers, and help our broker partners identify the signs of vulnerability when transacting on behalf of customers. This includes data protection law, Mental Capacity Act (England & Wales 2005); Adults with Incapacity Act (Scotland, 2000) and The Equality Act (2010).

These regulations expect us to presume that all customers have the mental capacity to make an informed decision about a loan or other financial transaction (this is to prevent discrimination against people with certain vulnerabilities) unless Kent Reliance for Intermediaries or any of our broker partners know or reasonably suspects that a mental capacity limitation exists.

In many instances, the vulnerability or their mental capacity does not affect the customer’s ability to manage their finances; however, it may impact their understanding of the implications of carrying out certain transactions. In these situations, we encourage customers to disclose any difficulty they are having with understanding the financial services we as a lender and you as a broker provide to them.

Identifying vulnerable customers

Where we become aware that the customer displays any of the key four factors outlined above, before recording any details, the explicit consent of the customer will be obtained by the broker. Where the customer is physically or legally incapable of giving consent, we may record the information to protect the vital interests of the customer.

Where a vulnerable customer is identified, our systems and internal processes are sufficiently flexible to ensure the customer’s individual needs are considered in an appropriate and sensitive manner. Details of the vulnerability will be recorded on the customer’s account to ensure we can easily identify the customer and their vulnerability in all future interactions.

We will explain to the customer what information is being recorded and for what purpose their information will be used. More information as to how we use customer’s information can be found in our Privacy Policy

Our employees have received specialist training to agree and determine the most appropriate action required. If a vulnerable customer is not identified during the early stages of their financial offering with us, we may not be able to address the customer’s needs appropriately when managing their loan.

Evidence of the vulnerability may be sought from the customer, or an appropriate third party (with the customer’s consent). Evidence is only requested in a pragmatic and sensitive manner. Evidence is not likely to be requested if it’s likely to cause additional distress to the customer.

Protecting against scams

Anyone can be a victim of rogue traders, conmen or unscrupulous relatives. Many older or vulnerable customers can fall victim to scams by rogue traders who then demand large sums of money or take financial advantage. We acknowledge the importance of identifying those customers that could potentially fall victim to such activities.

Notifying us of vulnerability

If you are dealing with a vulnerable customer, or believe you yourself may be one, you should contact us here.

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