What Is A Vulnerable Client?

What is a vulnerable client and how do we assist them? We work with a variety of clients and some of these individuals may be considered vulnerable by virtue of their age, disability or circumstances. We therefore have a policy for dealing with these clients appropriately, fairly and consistently.

Assisting a vulnerable client will result in us, as staff, being flexible in our approach to communications and also being empathetic to any specific needs or concerns they have.

What is a vulnerable client?

The Financial Conduct Authority (FCA) defines a vulnerable client as:

Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.

We are mindful that many clients in vulnerable situations may not think of themselves as being ‘vulnerable’.

Types of vulnerability

There are a number of factors that could result in a client being deemed vulnerable on a sporadic or temporary basis. A vulnerable client could be considered to be anyone who by virtue of their health, age or circumstances may be less able than others to: 

  • Realistically and objectively identify and prioritise their own needs, 
  • Fully understand the risk, cost or implications of any advice provided, 
  • Assess information in the usual format, for example, orally during meetings or visually in respect of written advice. 

This means that we would consider individuals affected by the following factors to be vulnerable:

Health Related

Physical disability, severe or long-term illness, mental health problems, addiction, low literacy, numeracy and financial capability skills.

Life Events 

Retirement, bereavement, relationship breakdown, income shock, caring responsibilities, domestic abuse (including economic control), people with non-standard requirements such as ex-offenders, care leavers, refugees.


Low or erratic income, over indebtedness, low savings, low emotional resilience.


Low financial capability skills, poor literacy and numeracy skills, poor or non-existent digital skills, learning impairments, no or low access to help or support, caring responsibilities (including operating a power of attorney).


Being over the age of 80 although this is not absolute – this could be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health, not being comfortable with technology.

Being young (associated with less experience).

Not possessing standard documents or credit history (for example armed forces personnel returning from abroad, ex-offenders, care-home leavers).

The presence of one or more of the above factors does not necessarily mean that the client is vulnerable. We would ensure that each of our advisers assess the client’s personal circumstances and ensures that every client is treated individually and with respect and empathy.

Identifying a vulnerable client

To be in a position to identify if an existing or potential client falls within our definition of a vulnerable client, we make sure through our meetings, both initial and ongoing, clients are asked about:

  • Personal situations,
  • Family situations,
  • Health issues.

As a company, we record the responses of our clients in a ‘fact find’ document which is associated to each client. If the adviser thinks the client is vulnerable, notes would be made, using where possible the client’s own words. The recording includes both reasons why a client would be considered not vulnerable as well as vulnerable.

If you would like further information about how we deal with vulnerable clients, then please get in touch.

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