Vulnerable customers

It is important to recognise that anyone can be or become vulnerable at any point in their life, and some customers may be at a higher risk of harm than others. Metro Bank uses the same definition as the FCA:

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.

Metro Bank is able to offer extra support to help make banking easier for customers.  With their consent, we can make a note on their accounts about any extra support they need.  This means they won’t need to mention it again, and our colleagues can make sure we always offer the right help in the future.

If the customer is happy to discuss and has given their permission, please ensure you record that the customer is vulnerable within the application notes, along with any supporting information.

Our Mortgage Servicing Team will give the customer a call back during onboarding to confirm the additional support that we will provide.

Disclosure of vulnerabilities will not negatively affect their application but will help us to make sure our customers get the best service both during the mortgage application process and after completion.

For an existing Metro Bank customers who are in financial difficulty and who need specialist support, please advise the customer to call the mortgage servicing team on 0345 319 1200. If you’d like to deal with this on their behalf, we will need a signed letter from your customer giving authority for you to do so, or for the customer to be present when you call.

Keep in mind that:

• Some customers’ personal circumstances can be permanent. For example, they may have a learning difficulty which means they will always need us to make reasonable adjustments when serving their mortgage needs
• Other customers may have a temporary personal circumstance, which means they could need additional support for a set period of time. For example a victim survivor of financial abuse may require help regaining control of their finances and independence
• Customers can also experience multiple drivers of vulnerability which means they have more complex needs and are more susceptible to harm. For example a customer that has low financial resilience may also struggle with their mental health.

Metro Bank seeks to help all customers secure the mortgage they want, but it’s important that they understand the long-term commitment and if it’s right for their circumstances.

You should look out for any evidence that a potential customer could be vulnerable and take extra care that they are not entering into a commitment which they don’t understand or may not be in their best interests.

Vulnerable customers may require further help with their mortgage application and the following information in this document will provide you with guidance on what you should do in these cases

You can use BRUCE to help identify vulnerability when you are interacting with your customers:

• Behaviour and talk: is the customer acting out of character? Look for indicators of vulnerability through the customer’s behaviour and speech
• Remembering: is the customer experiencing problems with their memory or repeatedly requesting information? Is the customer confused when asked basic questions such as personal details?
• Understanding: is the customer showing they understand all of the information they are being provided with? Are they able to replay that information to you in a coherent manner? This would included the customer showing they understand the potential consequences both of making or not making their decision
• Communicating: can the customer communicate their thoughts and questions and are they ultimately able to make an informed decision?
• Evaluating: can the customer weigh up the information options open to them to make an informed decision?

A negative response to one or more of these questions, at any time during your interaction, suggests that further clarification is required as the customer could be vulnerable.

Communication cycle

When it comes to having a conversation with customers who may need additional support, we suggest using the communication cycle. Below is an image of the communication which shows the 4 stages and their definition:

The communication cycle allows a two-way conversation so that the customer is fully involved and gives them the opportunity to express their views. The communication cycle has a huge impact when it comes to vulnerable customers as it allows the customer into the conversation by asking further questions if needed and ensures that we are listening to exactly what is being said so that we are fully informed. We are then able to use the acknowledge section to confirm our understanding and show the customer we have listened.

You can use TEXAS to help you to structure your conversation where a customer has disclosed personal information indicating they need additional support.

• T - Thank them, as it may have been a big step for the customer to   share their situation.  It’s important to acknowledge this and   put them at ease
• E - Explain any information will be captured and used to support them   in identifying and recommending a suitable product or service,   and may reduce the need for them repeat to themselves in the   future
• X - The customer must provide explicit consent and confirm they’re   comfortable for you to record and share any sensitive information   about their circumstances
• A - Ask some additional questions, for example, do you require any   additional time to make a decision to proceed? Is there any   additional support you would like?
• S - Signpost any potential support required, e.g. are there any   appropriate third party support groups or charities which may help   the customer?

At Metro Bank, we are all about providing unparalleled levels of service and convenience to our customers; this means identifying when customers are vulnerable or are at risk of becoming vulnerable.

If the customer is happy to discuss and has given their permission, please ensure you record that the customer is vulnerable within the application notes, along with any supporting information.

Our Mortgage Servicing Team will give the customer a call back during onboarding to confirm the additional support that we will provide.

Disclosure of vulnerabilities will not negatively affect their application but will help us to make sure our customers get the best service both during the mortgage application process and after completion.

For an existing Metro Bank customers who are in financial difficulty and who need specialist support, please advise the customer to call the mortgage servicing team on 0345 319 1200. If you’d like to deal with this on their behalf, we will need a signed letter from your customer giving authority for you to do so, or for the customer to be present when you call.