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By identifying vulnerability and offering the right support, we can improve clients’ experience and outcomes.
Aldermore’s 2025 programme of Get More with Aldermore webinar sessions continued in September with an important discussion on vulnerable customers.
This sensitive and insightful presentation featured two guests – Michelle Ash, national account manager at Newcastle for Intermediaries, and Aldermore’s risk control specialist, Gemma Lees.
Together, they explored how we can identify vulnerability, overcome disclosure challenges and work together to deliver better outcomes for clients.
Michelle began by giving us the FCA’s definition of a person with characteristics of vulnerability:
“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”
She stressed that all customers could become vulnerable at some point in their lives, even if they are not vulnerable now.
The regulator identifies four key drivers of vulnerability:
As Michelle pointed out, we can all recognise some of these in friends, family, colleagues and ourselves. Think about how many people are affected by events such as divorce or death, especially in mid-life, where this becomes more prevalent. If that vulnerability was formally acknowledged, all those people may be able to access better support.
Next, she gave us a timeline and a brief recap of recent rules, publications and research that have shaped the current view. All of these are useful for brokers, including:
Michelle highlighted one of the most common broker questions: who is responsible for disclosing vulnerability at which stage of the mortgage process?
This is addressed in the UK Finance Customer Vulnerability Disclosures principles, which say:
“Ownership of and responsibility to declare customer vulnerability to the lender during the mortgage application journey will sit with brokers (assuming a customer obtains a mortgage via this channel). Brokers should obtain consent from their customers to share vulnerability information with the lender.
“Typically, following completion of the mortgage, the broker’s ownership and responsibility to declare customer vulnerability to the lender ends. The ownership and responsibility to support the customer transfers to the lender until the mortgage is redeemed.”
Despite brokers frequently meeting customers with characteristics of vulnerability, they don’t always disclose this to lenders.
Smart Money People and Newcastle Building Society’s survey revealed common barriers to disclosure, with 58% of brokers saying they’re unsure how to disclose vulnerability to a lender.
Other reasons were:
It’s clear that brokers need better guidance, consistency, and simpler or standardised forms to make disclosure easier, and there is work underway to improve this.
Michelle also pointed to technology that already supports brokers to identify and disclose customer vulnerabilities, including Mortgage Broker Tools, Knowledge Bank, L&G Ignite, Experian Support Hub and The Vulnerability Registration Service.
Next, Gemma Lees explained how Aldermore has improved its support for vulnerable customers.
Aldermore usually receives disclosures of vulnerable characteristics when they have started to have an impact on the client’s finances, such as money worries, or when a life event, like divorce, is affecting them. But she added that vulnerable characteristics are not unusual: one in five adults has a reading age of about 10 years old, while one in four experiences a mental health problem.
Gemma explained that Aldermore undertook a gap analysis in 2024, reviewing where we were compliant with FCA guidance, identifying where further work was needed and creating a plan for continuous improvement. This is not a “one and done” exercise: it will be regularly reviewed.
Changes already made because of the gap analysis include:
For colleagues: a new Vulnerable Customer hub and toolkit, case studies, signposting resources, specialist training, and Vulnerable Customer Champions.
For customers: removal of arrears and direct debit fees, a forbearance product, and the introduction of a Vulnerable Customers Clinic, which meets to discuss individual cases. One case involved an acrimonious split with signs of financial coercion, so the clinic team was able to adapt policy, waive higher charges and work at the customer’s pace.
For processes: clearer capture of vulnerability information, system flags and warning notes that are visible across back-office systems.
We recently published a broker guide to identifying and managing vulnerable customers. It supports brokers with identification, how to tell us and what further support is available.
Gemma shared some cases Aldermore has received, which demonstrated poor practice, including a recently bereaved customer not having their vulnerability flagged, leading to distress during the mortgage process. Another involved a deaf customer, where only voicemail contact was attempted to discuss arrears by the previous lender, leading to more serious defaults.
There was good practice too, including a broker who disclosed a client’s dyslexia, enabling Aldermore to adapt our communication and ensure continuity of care throughout the mortgage.
Supporting vulnerable customers isn’t just about compliance – it’s about building stronger, longer-term relationships.
Brokers don’t need to be therapists, but you do need to spot vulnerable circumstances, understand support needs, disclose them to lenders and signpost clients to support where appropriate.
If you believe your client may have vulnerabilities, please use our Vulnerable Customer support form on the intermediary site for new mortgage applications.
If the mortgage is already in place, you can let us know by phone so we can offer the right support.
This prevents clients from having to repeat sensitive details and allows us to make the right adjustments, such as clearer communication, extra time for decisions or tailored account support. Disclosure is confidential and it won’t affect the lending decision.
Brokers can tackle hesitancy from their clients by explaining why disclosure benefits them and being clear about how the information will be used.
You’re often the first to spot signs of vulnerability and can make the crucial decision to disclose. By working hand in hand with lenders, you can help us ensure clients are treated with empathy, fairness, and consistency, and that no one falls through the cracks.