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Consumer Duty: communicating with vulnerable consumers

How to make your communications work with the new regulations.

The FCA recognises 23 characteristics of vulnerability spread across four ‘drivers’: health, live events, resilience and capability. It says that over half of UK adults have at least one characteristic at a given time. The sheer number makes the task of auditing your communications and changing them seem very complex. But in fact, whichever vulnerabilities you’re most concerned with, the impact – and the changes you can take – are often very similar.

You’re communicating with people whose ability to absorb, process and act on new information is impaired. Looking up a phrase they don’t understand, referring to a document you sent them 18 months ago, or logging into their online account may be more than they can face. They’re not in a strong position. So, to deliver a good outcome for them, and to comply with the Consumer Duty, your communications will have to do more of the heavy lifting. Here are three ideas to get you started.

Start at the beginning

A stressful situation or event – from a bad diagnosis to a relationship breakdown – can push preexisting knowledge beyond your customers’ reach. Stress interferes with our ability to form and recall memories. Our bodies release a hormone, cortisol. It’s why we always seem to lose our keys when we’re already in a rush.

So, if you’re writing to someone you know to be in a bad way, a gentle introduction will help your letter land much more easily. What’s the ‘story’ of your correspondence with them? When did you last write to them, and why? What course of action was agreed? And what’s happened since? Put this stuff at the start of your letter and your customer is much more likely to understand it.

Go light on working memory

Our brains hold and process new information in what’s called our ‘working memory’. Start reading a sentence, and it’s held in your working memory until you get to the end and process its meaning. But ask someone to remember too much, even at the best of times, and it’ll soon stop sticking. This is called cognitive load theory. And when someone is subject to stress from (say) a major life event, their working memory is seriously impaired. The last thing you want to do is overload an already vulnerable person.

You can help by using shorter sentences and simpler words that won’t tax their ability to understand. Rather than complex maths, show worked examples – where the impact of (say) a change in contribution rates to a pension is demonstrated on a fictional person. And make sure pages are clearly and sparingly laid out, with plenty of white space to help the most important information stand out.

Cut down on unnecessary contact

Most of us know how quickly we can start to feel overwhelmed when there’s already a lot on our plate. And modern life – with constant, real-time, multi-channel intrusions – can make this effect particularly acute. Imagine, for example, that you’re dealing with money problems and an official-looking letter arrives in the post. It could trigger a full-blown panic response before the letter’s even open.

You can do a lot to help vulnerable customers’ state of mind by making sure they’re taken out of all the usual sales and marketing activity. They shouldn’t get any letters, emails or calls that aren’t essential and don’t relate to products and services they’re already using. This will reduce the increased stress that’s often associated with the drip-drip-drip of regular, unwelcome distractions at a difficult time. And it makes it easier for them to identify important, relevant communication that can give them information on which they can act positively.

The Consumer Duty guidelines are full of practical advice on making the language your firm uses clearer and more effective. Treat this as an opportunity to embrace inclusive communication and the result will be stronger, longer-lasting client relationships.