A practical guide for complaint case handlers. Dealing with vulnerable customers

Introduction

If you’ve worked in complaints for more than a week, you know that no two customers are the same, and some need more than the standard process to get to a fair outcome.

Vulnerability isn’t rare; it’s part of complaint handling and the onus is on you and not the customer to identify whether additional support is required.

'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' - FCA

This might be a long-term illness, sudden bereavement, fluctuating mental health, or even retirement. The point is that you won’t always be told. Often, it’s down to you, the person speaking to the customer, to spot the signs, record them accurately, and adapt how you handle the case.

And under the FCA’s Consumer Duty, your actions need to result in outcomes for vulnerable customers that are as good as those for everyone else.

🎗️ Some customers may object to being labelled as ‘vulnerable’, and we've found that phrases such as ‘requiring additional support’ are much more appreciated.

1. Recognising vulnerability in real life

The FCA describes four drivers of vulnerability and some of the characteristics falling under each driver heading:

• Health: – includes physical disability, severe or long-term illness, mental health condition, addiction, or low mental capacity.

• Life Events:– includes bereavement, relationship breakdown, domestic abuse, caring responsibilities, and migration.

• Resilience: – includes low emotional resilience, erratic income, and over-indebtedness.

• Capability: – includes low knowledge of managing finances, poor literacy or numeracy skills, and poor English language skills.

Some cases are obvious: a customer tells you they’ve been diagnosed with a long-term illness, or you can hear that English isn't their first language. But many cases require active listening in order to be identified.

Examples:

• A customer struggling to keep track of what you’ve said may be experiencing cognitive difficulties.

• Someone who avoids phone calls might have anxiety or hearing impairments.

• A change in tone or urgency could indicate sudden life changes like job loss, caring responsibilities, or another major life event.

💡 Tip: Don’t automatically dismiss an 'unpleasant or unusual mannered' customer. If something doesn't seem right, maybe there's more going on. If you’re not sure, flag it for review with your team leader.

2. The 4 R’s to support vulnerable customers

The 4 R’s are a simple way to structure your approach when you suspect or confirm vulnerability:

• 1. Recognise:– Identify vulnerability markers through active listening, questioning, and observation.

• 2. Record:– Capture details clearly in the system so anyone else handling the case is aware.

• 3. Respond:– Make reasonable, proportionate adjustments that meet the customer’s needs without causing unnecessary delay.

• 4. Review:– Reassess regularly, especially for transient or intermittent vulnerabilities, to make sure adjustments remain appropriate.

Following the 4 R’s ensures you act consistently, build an evidence trail, and support good outcomes, no matter who picks up the case next.

3. Using the right frameworks and making them routine

Frameworks aren’t just for training courses. They’re a safety net for when you’re working under pressure. Here are three well-known frameworks recognised by the FCA and Money Advice Trust:

• TEXAS -Thank, Explain, eXplicit consent, Ask, Signpost: used to manage disclosure and record details lawfully.

• BRUCE - Behaviour, Remembering, Understanding, Communicating, Evaluation: useful when you need to assess capacity and resilience.

• IDEA - Identify, Design, Evaluate, Adjust: works well with the FCA's MALD (monitor, analyse, learn and develop) strategy to build an organisation-wide approach.

When your system prompts you to run through TEXAS or BRUCE, follow it step by step. These checks make sure you’re recording and responding consistently, and that your actions will stand up to review.

4. Adjusting without adding unnecessary delay

Once the vulnerability is identified, your role isn’t about slowing things down, it’s about acting quickly and thoughtfully.

Examples of a fast, fair adjustment:

• Offering a different communication channel.

• Breaking down next steps in plain language.

• Arranging for additional support with a third party trusted by the customer.

• Offering alternative ways to manage the issue.

Record these adjustments clearly, with review or expiry dates if the need is temporary.

5. Why collecting evidence is your shield

You might think you’re doing the right thing, but without clear notes, your work can’t be defended. The Financial Ombudsman Service (FOS) often upholds or rejects complaints based on the quality of reasoning and evidence, not just on what was done.

That’s why your notes, emails and decisions need to show the:

• Vulnerability markers you identified.

• Adjustments you made.

• Reason as to why the adjustments were proportionate.

If you want to see how this evidence fits into a firm’s systems, data, and compliance controls, read our Embedding vulnerability in complaint handling; a guide for leaders. It gives you the bigger picture on how these individual actions help your firm meet compliance and governance objectives.

6. Learning from real cases

Regulators take vulnerability seriously because missed needs have real-world consequences.

For example, in a case study shared by the Financial Ombudsman Service (FOS), a consumer complained that their bank acted irresponsibly after they made a high volume of gambling transactions. The Ombudsman found that the bank had not identified or acted on clear signs of potential vulnerability and financial harm and upheld the complaint.

Missing vulnerability indicators can directly impact a customer’s well-being and your firm’s regulatory risk.

Handling vulnerability well isn’t about doing more work; it’s about looking after your customers and following the right steps, every time. Recognise. Record. Respond. Review. This is how you protect your customer, your decision-making, and your firm’s regulatory risk.