Identifying and assisting vulnerable customers

Many 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.

Recognising vulnerability

The FCA’s vulnerability guidance makes it clear that it expects firms to ensure that staff have the skills and capabilities to recognise vulnerability and respond appropriately to individual customers’ needs so they can treat them fairly.

Staff should be capable of recognising and responding to needs:

  • where the consumer has told the firm about a need
  • where there are clear indicators of vulnerability
  • where there is relevant information noted on the consumer’s file that indicates an additional need or vulnerability.

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