None so blind

My first marketing role was as part of a 'Sales Tactics' team supporting the direct sales arm of Friends Provident in the mid-90s. But it wasn't the first time I took an interesting in marketing.

Just prior to taking up this role, I'd become almost obsessively interested in sales aids - specifically how many Friends Provident had produced for advisers (the answer was a LOT - dozens in fact) and how many were actually used by advisers (the answer, based on feedback, was virtually none).

Why the discrepancy? As far as I could see, the sales aids were well-constructed, well-written and clearly designed to help an adviser help their customer to understand the vagaries of PHI or Critical Illness or whatever.

Weird, right?

Well, no not really. The answer to this frustrating conundrum was actually startling obvious: no-one from Friends Provident had ever asked an adviser's opinion on what makes for a good sales aid. Or indeed what specific part of the advice and recommendation process would be best served by a sales aid.

Never.

Not once.

Instead, members of the Friends Prov marketing team - who were experts in their product field but almost entirely without any direct-to-consumer advice experience - produced what they felt would be the most helpful thing to get across the USPs of their product.

Well-meaning, yes, but well off the mark. Designed to help? Absolutely! Of any help at all? Meh, not so much. Theoretically sound, but practically useless.

You could say, to bastardise a oft-quoted proverb, that the road to bad customer outcomes is paved with good intentions.

I was reminded of this genesis of my own marketing career by a couple of articles that appeared recently relating to vulnerable customers. Vulnerability is a constant 'hot topic' in the later life lending market, and for good reason. But even if these articles shine just a narrow spotlight on the subject, rather than illuminating to entire debate, our industry is in danger of paying lip service to this crucial area of financial advice.

In the more recent article, which you can find here, the FCA claims that some firms have failed to think about vulnerability proactively. Although singling out the Wealth Management sector in particular, it's nonetheless a worrying observation for the Regulator to make about any part of the Financial Services market - and not the first time they have done so in recent years.

Another article that caught my eye a few months ago was this one, based on research conducted by Smart Money People on the first anniversary of Consumer Duty, which discovered 84% of customers say they have seen "no difference" in the way financial providers treat them since the implementation of the new regulations.

Ouch.

Now, it would be wrong to suggest that this industry doesn't treat vulnerable customers well or that it hasn't tried to do better. And of course there is no such thing as perfection, 10/10, 100% when it comes to such things - to claim otherwise would be like poor old Charles Duell, Commissioner at the US Patents Office, who it's said claimed in 1899 that his office would soon have to shrink in size because "everything that can be invented has been invented".

There will always be a better process, an innovation in technology, a new insight into consumer behaviour at some point that will propel us to push the boundaries of "good outcomes" even further. That's human endeavour for you.

But what these articles do suggest to me is that we may be asking the wrong questions. Or perhaps, worse still, asking the wrong people the wrong questions.

Are we in danger of assuming too much and, deafened by the sounds inside our own well-intentioned echo chamber, presuming that we have done all we need to do, rather than all we could do, in order to meet the regulatory demands and advice needs of the most vulnerable of clients?

Maybe.

After all, if the very people that new regulations and safeguards are designed to protect are saying - very definitively - that they have seen no difference in the way they were treated pre- and post-Consumer Duty, then something isn't right. And as an industry we can't simply shrug our shoulders, compare notes with our peers and reassure ourselves that the Consumer Duty Vulnerability Box has been well and truly ticked.

It's one of the reasons why we developed a Vulnerability Scorecard as part of the Advice Guru proposition. I'm not going to pretend this is super-scientific - there's only so much data you can capture and interrogate through a simple online quiz - but it is at least an attempt to provide a way of opening up a more honest and raw conversation about vulnerability between a client and their adviser.

There's lots of talk about vulnerability in our sector, lots of well-crafted processes and I've lost count of the number of fantastic guides and internal documents I've seen designed to help highlight the issue. But there is, in my opinion, a dearth of practical tools that help advisers (and consumers) face into the nutty, uncomfortable and sometimes embarrassing subject of physical, emotional and financial vulnerability.

We can only truly tackle the subject of vulnerability properly by asking the right people the right questions. Perhaps then we will begin to make the progress and improvements that we all want to see the industry achieve.