The first comment was in response to the article: How Consumer Duty will impact brokers dealing with financial vulnerability – Comentis
Arron said: “A recent compliance training session cited the following statistics on vulnerability: 19 per cent of workers have a disability; 16.4 per cent have very low literacy skills; 7.7 per cent do not speak English as their first language; 49 per cent of working adults have poor numeracy; 67 per cent of adults have suffered mental health issues since the lockdowns with higher rates for younger adults.
“These are a fraction of the possible definitions, but, in a Venn diagram, the overlaps would make it difficult to find customers who are not deemed vulnerable in some way.”
He added: “And remember, vulnerability can change and often it is not visible or easily detectable. Therefore we must document each file with full awareness a client can ask for a copy; and those notes will need to stand the scrutiny of hindsight if a complaint is received years from now.
“This could be the new endowment scandal with the onus on brokers when it comes to claims.”
Acknowledge lenders keeping the market open
Our next top comment was on the feature: Lenders pulling products to deal with ‘shocking’ service levels, brokers suggest ‒ analysis
Arron commented again, saying: “Lenders are trying to cope with record levels of business. Those that invested in technology and revised their criteria to remove antiquated checks (eg certifying documents, mortgage statements duplicating credit reports or signed declarations) are better able to cope than those that have stubbornly stuck to what they know or pushed progress into the long grass for far too long.
“Lenders could simply close their doors until they catch up or increase prices by one per cent, but that would cause more problems for borrowers.”
He added: “While a few Luddite lenders are causing us the most problems, we should recognise the efforts of the rest in trying to keep the market open.”