Published by Jessica Weisman-Pitts
Posted on October 31, 2022
4 min readLast updated: February 3, 2026
By Tim Farmer, Co-founder and Clinical Director at Comentis
The need to ensure vulnerable customers obtain good outcomes – the thread that runs through the Consumer Duty – is crystalising. However, for financial advisers to make truly informed decisions on the important topic of customer vulnerability, all parties involved in the distribution chain will need to work much more closely together and take a joined-up approach.
If all parties in the distribution chain start to share their vulnerability data more intelligently, and take a more joined-up approach, they will begin to offer a considerably improved customer experience. But most importantly, they will help to ensure that their customer feels truly safe when sharing their story. After all, having to go through the emotional turmoil of sharing their experiences again and again – to multiple different providers – is only going to cause the customer greater anxiety. In some cases, it may even lead to them feeling unsafe to share their story.
I believe safely sharing customer data around vulnerability can actually ease a customer’s anxiety, reduce their stress and help to engender long-term trust between customer and adviser. I would even go so far as to say that a lack of joined up thinking can, unfortunately, allow some incredibly vulnerable people to slip through the net. Ultimately, failing to share data that is this important will only be to the detriment of the individual.
When we look at a customer / adviser relationship, we will of course note that who the customer is speaking to and where that conversation takes place will affect the way they feel. For instance, they might open up during a vulnerability assessment because they feel like they’re in a safe space, but then may not in further vulnerability assessments because they don’t feel safe or simply don’t trust one of the other providers they’re engaging with.
Alternatively, the customer might believe that because they have already laid their vulnerabilities out to one provider, they shouldn’t need to do so again to someone else. After all, they might (understandably) assume that all salient information would be passed over.
The other concerning possibility is that when a person tells a difficult story again and again, they forget who they have told which detail to and leave certain elements out the next time they tell it, merely because that information has already been shared at another stage. You can begin to see, without a fully joined up approach, how much potential exists for important information to be dropped.
What we need is an industry standard of information sharing, that works across all product providers. This not only needs joined up thinking, but smart ways of working from a technology point of view. Providers should be using the same platform for inputting key information, and indeed, for intelligently digesting the vulnerability data that comes out.
It’s here that I believe a triage system would really benefit the financial services industry. Creating a triage system, much like you would experience when a patient physically attends an Accident and Emergency room at hospital, would allow all the right information to be gathered upfront and then shared safely and correctly down the distribution chain.
This would ensure that the customer avoids needless repetition, continues to feel safe sharing their story in a different setting and would not have to worry about missing out any key details. It will also take the emphasis off the customer, who is going to be feeling very raw and exposed and puts it back onto the providers. After all, as the FCA clearly states, this is their responsibility.
The key here is transparency, detailed disclosure and ensuring all providers adhere to the same technology and ways of working. A practical and pragmatic guide or industry standard recognised by all would of course be very beneficial too. Until then however, a collaborative solution by all providers must be agreed – and it must prioritise the customer.
Customer vulnerability refers to situations where individuals may be at risk of harm due to their personal circumstances, making them less able to manage their financial affairs effectively.
A triage system is a method used to prioritize customer needs and gather essential information efficiently, ensuring that vulnerable customers receive appropriate support promptly.
Financial advisers provide guidance and support to clients regarding their financial decisions, helping them navigate complex financial situations and improve their overall financial well-being.
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