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The UK market has seen household consumer based credit continue to increase at rates of up to 10% over the last twelve to eighteen months and if this market trend continues coupled with the much hyped interest rate hikes there is an inevitability that more individuals who already have high level of debt will experience further detrimental financial impact.


There are numerous articles which highlight the plight of low income families of which a high percentage are currently experiencing some form of financial hardship, but what about those families in the so called “mid income” bracket that will be impacted by interest rate hikes and the continued increases in living costs?

The general consensus is that as debt levels increase so will the volume of those consumers who find themselves vulnerable.

The FCA continue to focus on the area of “vulnerability” and indeed comment that there is a need for more emphasis on consumer vulnerability, this coupled with the requirements that regulated organisations must have a defined and robust approach to this area means that organisations need to look closely how they deal with an ever increasing vulnerable sector.

The FCA defines vulnerability as: “Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

There is an argument that we are all vulnerable in some shape or form, however understanding types of vulnerability and those that may be particularly vulnerable is key, and subsequently dealing with those situations is of vital importance in today’s economic and regulatory landscape.

So where do frameworks and tools such as TEXAS, BLAKE, IDEA, SPIDER and BRUCE, come into play in this area?

Ensuring front line customer engagement in the vulnerable sector is a high priority is key, it is necessary to provide a fair and appropriate journey for the customer who finds themselves in a vulnerable situation be it with mental health issues, suicidal issues, critical/terminal illness, bereavement, addiction or financial issues.

Dealing effectively with these scenarios can be challenging especially when tasked with providing the necessary evidence of a robust customer centric approach, but how should this be done?

Front line training specifically aimed at the vulnerable sector is important and having dedicated customer support teams is another way to deal with those situations.

Should organisations use scripting to deal with these situations - basing the scripting on the principles and guidance highlighted in the tools as mentioned above is one way, but does scripting really enable an effective two way conversation? After all I’m sure we have been subject to calls where the conversation becomes monotonous as the caller goes through a script.

Building a call framework rather than scripting allows for a more interactive conversation thus enabling the vulnerable customer to feel that it’s more of a conversation than a tick box exercise will be beneficial to all parties concerned, and will undoubtedly lead the customer to be more forthcoming about their current situation.

Asking the questions in the correct manner, in the correct language and tone helps gain a full understanding of the customers circumstances and furthermore allows the front line agent to listen to responses, and perhaps more importantly, the tone in which they are responded in. All of these signs helps fully understand the customer’s circumstances and builds rapport and trust whilst demonstrating empathy.

So whilst its acknowledged that front line engagement is pivotal to ensuring the appropriate activity is undertaken, It is just as important to ensure that a technological platform is in place as an enabler to ensure information is obtained, recorded and has the functionality to subsequently to drive the appropriate strategies. One benefits the other, after all there is no point having well trained, knowledgeable staff that are unable to ensure the appropriate information is recorded or that the system cannot accommodate the needs of the specific customer in order to assist them.

Let me know what you think, leave a comment or send me an email at Visit our web page to find out more about CGI in Collections.

About this author

Jamie McGrath

Jamie McGrath


Jamie has over 25 years’ experience in senior management positions across the debt recovery, debt purchase, tracing and enforcement market sectors. Operational experience 25+ years Jamie is a Special Advisor to the Credit Services Association Board and a Member of Chartered Institute of Credit ...

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