The Later Life Lending Summit session on Vulnerability was a fantastic opportunity to share best practice and learn, with real cases from the Financial Ombudsman Service and the findings from Inclusive Outcomes’ research with practitioners across the later life lending sector.
I was struck by how much the debate has progressed in the last year, moving on from wrestling with policy and regulatory frameworks to talk about real life examples and experiences, and consider how we can mature the support we give customers with vulnerabilities. I reflected that Consumer Duty was less a big mindset shift and more an evolution – the Equity Release industry has been focused on supporting all our customers and aware of vulnerabilities for much longer.
When asked what change the panel would prioritise over the next 12 months, communication shone through at all stages of the journey. I reflected on the need to equip and empower our people to identify where customers may need different levels of support and give them flexibility to adapt processes to meet their needs. Part of that is training, and we have partnerships with Alzheimer’s UK and Citizens Advice to put that into practice.
Fully embedding best practice will take clear measurement, as the Inclusive Outcomes research stressed – having defined Good Customer Outcomes and Poor Customer Outcomes, at Aviva we’re now refining and developing the MI we use to measure them.
We need to design for vulnerability at all stages of the proposition – consider health and lifestyle factors in our pricing, with customers potentially receiving lower interest rates to reflect health conditions; we’ve introduced behavioural bias training from Fairer Finance, and updated our Customer Propositions design framework to ensure foreseeable harm is considered and mitigated at the design stage.
It was encouraging to be part of a panel considering vulnerability from such broad angles, and to see a lot of shared ground. Ultimately, it comes down to people – understanding the people we support as customers and empowering the people we work with to adapt to deliver good outcomes. With more research and best practice to come, I’ll look forward to seeing even more progress at the summit in November.
