Set up in 2021 by co-founders Jonathan Barrett and Tim Farmer, the firm provides a questionnaire to brokers available either through an app or CRM integration.
It flags up any circumstances which could cause a vulnerability then signposts brokers towards next steps for additional support.
The tool has been live for a year and is being used by 27 firms. Brokers can buy a license from £12 a month.
Medical and technological backing
Barrett has over 20 years’ experience spanning across fintech, business strategy and mortgage consulting.
His previous experience includes roles at NGM Financial Services Consulting as senior consultant and mortgage lead, director of mortgages and financial services at The Ark, and consumer and strategy director at Legal and General. There he helped to launch Legal and General Mortgage Service.
Most recently, he was director of business development and partnerships at ABAKA, a role he held for over two years where he provided financial institutions with digital communication solutions.
Farmer has over 25 years’ experience in the medical field, primarily in the mental health space.
He is considered one of the UK’s leading experts in the assessment of mental capacity, financial vulnerability and has worked as an expert witness for the Financial Conduct Authority (FCA) regarding these issues.
He was first approached by the regulator in 2014, and said it was there that he first noticed a “really big disconnect between how people engage [with mortgage advisers], how transactions are done and how [vulnerability] assessments are carried out”.
He said assessments tended to be carried out face-to-face, while transactions were done online. For this reason, he started to think of ways to bridge the technological gap and create a tool aided by his medical background.
Barrett also said firms were facing regulatory and social pressures to correctly assess and identify vulnerabilities in clients.
Barrett said: “To do that, without that clinical, mental wellbeing and mental health lens, you are completely missing the point.
“Our mission as a business is to put clinical assessment expertise in the hands of practitioners who have a responsibility to identify and support the mental health and wellbeing of their customers.”
Not enough official guidance
Barrett said there was not enough regulatory guidance around how to identify vulnerabilities beyond brokers being told that it was their duty to recognise anyone who seems to be lacking resilience or capability.
He said advisers wanted to do the best by their clients, not just for regulatory reasons but because it is the best thing to do, however the current process was ad hoc with different firms using varying approaches.
Barrett said compared to someone like Farmer who had extensive experience working with mental health, it was “unfair to expect brokers to do this”.
“In all honesty, it is asking a broker to do what Tim does. And he’s had 20-odd years training doing it.”
Farmer said Comentis’ tool removed the barriers of getting a general practitioner or expert assessor involved, meaning clients could avoid processing delays and missing out on rates.
The questionnaire comprises a series of questions based on the four drivers of the FCA’s definition of vulnerability: health, life events, capability and resilience.
Farmer said: “The real key ones were around the capability and resilience because these are not just financial resilience or financial capability, they go beyond that. As a concept resilience is, ‘how will I cope and adapt when times get tough?’
“These are really important things to understand, because it helps the adviser understand how the client is going to react [to life stressors].”
He added: “Capability is about ‘how do I apply the knowledge that I have appropriately to the circumstance?’ And then starts to really dig deep into the understanding of why people are doing what they’re doing, and the decision making, which again, is a skill that is beyond most non clinicians and even a lot of clinicians.”
Later life focus
Brokers have told Comentis that the tool enables them to broach difficult conversations with clients, increase people’s understanding of their situations, and strengthen relationships between the two.
The firm has honed in on later life adviser firms, and Barrett said the response so far was “brilliant” as many were worried about meeting regulatory requirements for the fear they did not have the right knowledge and may miss signs. Barrett and Farmer said age alone did not make someone vulnerable, but rather how people reacted to things like cognitive decline and social isolation.
He added: “[Comentis] removes that growing burden of ‘what do we do?’ And I think in the equity release space, that’s even more pertinent.”
The firm has secured agreeements with Air Group and SimplyBiz. It is also working with lenders to get the assessment officially approved. In separate conversations, Stuart Wilson, CEO of Air Group told Mortgage Solutions that Comentis had gone out of its way to understand the broker market, while Richard Merrett, head of strategic development at SimplyBiz, said its brokers had responded positively to the tool.
Supplementing regulatory requirements
Anecdotally, brokers have said they find it easier to spot vulnerabilities using Comentis and were being made aware of clients who may not have raised concerns previously.
The chair of the European Board of Assessment helped Farmer to formulate the questions, and these have been validated by the International Test Committee and the International Congress of Psychology.
While Comentis said it was unlikely the FCA would ever approve Comentis as a single solution to spotting vulnerability, it felt the 2,000 assessments carried out so far were effective.
However, Barrett criticised the lack of an official, regulated standard of assessments for brokers.
He said: “All those checklists and other systems do is give brokers a record, or a means to record something in a structured format. They do absolutely nothing to actually support an adviser to understand, get insight and identify resilience and capability issues.
“You have to take a clinical psychology psychometric approach to actually do that. A checklist is a waste of time.”
He added: “What we know about the new consumer duty is the FCA is saying it’s not for the client to to prove that they’ve got vulnerability, it’s for [the broker] to prove that they don’t have a vulnerability.”
Comentis has different assessments for each sector including mainstream mortgages and equity release. The firm is currently developing a new version of its questionnaire set.
Farmer said this was partially down to broker feedback, while Barrett said: “With a new product, your first version should never last particularly long. Your first version is built on theory, practical experience and a lot of user testing.”
