Insurance advisers are being reminded to take care in the way they deal with clients who could be deemed vulnerable.

The Financial Markets Authority has indicated that it expects the number of vulnerable people in New Zealand to increase because of the ageing population and an increase in the number of migrants. It said financial services providers should consider how the design of vulnerability processes and practices could best support their business objectives.

Under the code of conduct for financial advisers, which will apply to all brokers and advisers from March 2021, advice must be given that is suitable, understood by the client and delivered with competence, knowledge and skill.

Training institution Strategi said that meant it was important that insurance brokers identified vulnerable clients and dealt with them appropriately.

Customers could be vulnerable due to health issues, life events such as an income shock or relationship breakdown, a resilience problem such as low income or lack of support, or issues with capability such as poor literacy.

Strategi said insurance advisers might notice that clients were becoming vulnerable if they made a change to their payment habits, such as missing a payment, stopped responding to phone calls or emails, asked the same questions repeatedly or exhibited signs of anxiety.

“Staff can feel uncomfortable asking clients questions that may be perceived as personal, for fear of upsetting them. However, with the right training, staff can learn how to ask these questions in a sensitive manner that helps the client feel able to divulge whether the service needs to be adapted for them.”

Good practice would mean taking a holistic approach, it said. “Every level of your business should understand the role they play in delivering good results to these clients. Vulnerable clients need to be considered throughout the whole client journey and in all interactions. This includes from how you design products, through to how advice is delivered.”

Management would establish processes to support staff to act flexibly and establish boundaries for them to operate within, products should be designed in a way that would not affect vulnerable clients adversely and front-line staff and advisers should identify clients who were vulnerable and implement policies with the flexibility to respond to client needs.

“Well-trained staff are often able to help vulnerable clients articulate their needs, by asking about their requirements at key stages during the client journey. This might include letting the client know they need to understand a little more about their circumstances when they are considering switching products. This may highlight if the client has had a change in circumstances which makes them more prone to being vulnerable, such as a bereavement. Staff can also learn a great deal from having the opportunity to share their experiences in dealing with vulnerable clients.”

They should then record the issue, respond in a way that was suitable to their needs and report what had occurred.

“Your professional duties require you to be satisfied clients understand the advice being provided. It is therefore prudent to check the client’s understanding at key points. If you deem the client’s level of understanding to be unsatisfactory, you should not sell the product to them. Consideration should also be given to the communication channels that you offer your services through and whether they might be excluding or disadvantaging particular clients. The broader the range of communication channels you offer, the more likely you are able to meet the needs of vulnerable clients.

“It is important to remember the regulatory framework firmly places the onus on you, as the financial advice provider, to meet client needs and deliver good outcomes for vulnerable clients. Due to the Covid-19 crisis, along with existing demographic changes within New Zealand, it is becoming more likely that vulnerable clients will form part of your client base. By ensuring you have well-trained staff who are able to identify and understand these clients’ needs and that can use that knowledge to adapt services appropriately, will help to ensure the needs of all your clients and your obligations, are met successfully. To be effective, this needs to sit within a robust framework of policies, processes, and controls.”

December 2020

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