The FCA’s ‘Guidance for firms on the fair treatment of vulnerable customers’ came into force in February 2021 and will be strengthened by the ‘A new Consumer Duty’ paper, which is currently out for consultation.
The MorganAsh Resilience System (MARS) allows mortgage advisers and firms to meet the 2021 FCA requirements for understanding and managing consumer vulnerability by giving a ‘resilience rating’ score out of ten, similar to a credit score. MARS is independent of both providers and products, and can be used by anyone in financial services, for any product or service.
Andrew Gething, managing director at MorganAsh said: “Just as a credit score is used to simply communicate wealth, MARS is used to communicate health and resilience.”
MARS works by collating multiple data points from consumers and their advisers, including health, life events, and personal wealth. The rating is then matched to the stage of engagement and the potential for consumer detriment.
The system works for all finance businesses, but for a high-risk or high-value product, such as mortgages and later life lending, more detailed information would be required, which is then independently verified. The client can either complete an online questionnaire or, if they are suspected to be vulnerable, they can be booked for an assessment with a MorganAsh nurse. Mortgage and financial advisers can input a client’s vulnerability information themselves too.
The objective measure provides consistent and essential evidence of regulatory rigour to compliance teams and the FCA. It can be used as a standalone tool, or integrated with a firm’s CRM via secure API links. MARS is already integrated with systems from Intelliflo and Iress, with more integrations planned. It is also being used by St James’ Place and its partners.
Robert Sinclair, chief executive at Association of Mortgage Intermediaries, said: “Firms need to understand the characteristics of their customers, and be able to manage and report the conduct risk. Firms’ progress to-date has largely been limited to subjective individual assessments which risk inconsistency and complexity in recording.
“A move to more structured assessments that can provide consistent and objective data will provide management information that firms can utilise. The resilience rating within the MARS tool would appear to be a positive first step.”
Keith Richards, chair of the Financial Vulnerability Task Force, added: “Given the often complex and technical nature of financial planning – which automatically places most people in a position of vulnerability because of knowledge and experience-based dependency – we must do what we can, at every opportunity. The current regulatory focus on vulnerability provides a timely opportunity to improve how we can recognise and address vulnerable circumstances, whilst also demonstrating individual care and empathy.
“Good practice principles and the use of fintech, such as the MARS tool, can greatly improve our ability to assess, store and communicate vulnerability across and between organisations.”