Identifying and assisting vulnerable customers

Most customers will be able to make decisions without difficulty.  However, a surprising number will encounter serious problems.  It is important that dealers and lenders are alert to these problems, and provide support to overcome them.


Customers often need to make a number of decisions or choices when they buy a vehicle.  It is important that they are provided with clear information to help inform these choices and are given the space and time they need to make careful decisions. 

Four parts to a decision

Customers must be able to do four things when making a decision:

  1. Understand the information provided to them (this could be about the vehicle, contract, or other issues)
  2. Recall key information about the vehicle, contract arrangement or their own personal information.
  3. Evaluate (‘weigh-up’) any options or choices they have been given.
  4. Communicate any questions they have, and their final decision to go ahead with the purchase.


Most customers will be able to make an informed decision without difficulty but some will struggle.  There are a number of common potential causes of mental capacity leaving the customer vulnerable and unable to make decisions:

  • a mental health condition
  • dementia
  • a learning disability
  • a development disorder
  • a neurological disability or brain injury
  • alcohol or drug use – including intoxication or use of prescribed drugs
  • language and literacy – inability to speak English and read/review paperwork or information

According to FCA CONC rules a firm’s primary focus should be on:

  • taking action to assess whether a customer can understand, remember and weigh-up information;
  • providing reasonable support to help customers make a decision;
  • providing customers with clear information and explanations about credit and the associated risks;
  • giving customers adequate time to consider the information and explanations provided and ask any questions. 
  • giving customers the opportunity to take information away to consider explanations, enabling them to make informed decisions at a later date;
  • carrying out appropriately robust assessments of the customer's ability to afford to make repayments.  Such assessments should not rely unduly on the information provided by the customer.