Accessibility and Tailored support

We’re here to help you identify and support vulnerable customers

Finding a suitable mortgage is one of the biggest financial challenges our customers face. And that’s especially true if they are vulnerable customers.

The FCA states we all have a duty of care to these customers, and TSB fully backs this.

We can help you identify if your customer is vulnerable and offer support throughout the mortgage journey.

What is a vulnerable customer?

The FCA defines this as “a person who, due to their personal circumstances, is especially subject to detriment, particularly when a firm is not acting with appropriate levels of care.”

It’s also important to realise that vulnerability doesn’t just happen to a minority. Anyone can become vulnerable at different times and there are several types of possible vulnerability.

Here’s a guide to how we categorise vulnerabilities.

Key drivers of vulnerability:

Low capability:	This includes poor literacy skills or numeracy skills, or a lack of understanding of financial products.
Low resilience:	Customers with limited ability to withstand financial or emotional shocks.
Negative life events:	Events such as bereavement, loss of employment, or divorce.
Health conditions:	Ongoing or chronic health conditions, including mental health conditions.

Tailored Support Need	Explanation	Examples (not limited to)
Ease of access	Customers who have limitations due to a physical impairment, that impacts their day to day lives.	Deaf, blind, mobility, dexterity.
Support interactions and communications	Customers who have limits with their cognitive ability to make decisions or require a little support from others to make these decisions.	Memory loss, dementia, neurodiversity needs, mental incapacity, English isn't first language.
Physical wellbeing	Customers who have serious or terminal illness impacting their day to day lives.	Disease, cancer, stroke, heart attack.
Mental wellbeing	Customers who suffer from illnesses that impact their judgements or thoughts to make reasonable and rational decisions.	Anxiety, depression, self harm, suicide, bipolar, schizophrenia.
Life event	Events that happen in a customer’s life that impact them for a short period of time. This can be financially, physically or mentally.	Bereavement, divorce, short term illness, house move, starting university, loss of job.
Managing finances	Customers who due to their financial situation, are not resilient to financial shocks.	Low income, income shock, socially reliant families.
Understanding finances	Customers, who lack knowledge, skills, or understanding of their finances, and make decisions on them.	Financial comprehension in complex scenarios, foreign language, age related limitations (old age, young adults/teens).

How TSB can help

Once we know about someone’s vulnerability, we take time to understand their requirements and then tailor the support we offer them.

This can be anything from providing documents in larger type to quiet spaces for them to meet us. See Examples of TSB’s support at the bottom of the page for more detail.

When to let us know

The best time to let us know about a customer’s needs is during the mortgage application process within Mortgage Pro.

Telling us about a customer's vulnerability will not affect their credit rating or our lending decision.

We ask a few questions so you can be specific and help us know how to support them at our end. Please:

Use the table above to help with your answers.
Ensure you have your customer’s consent to provide this information.
You can put much more detail into the box provided. Please add details and include any additional support required. Use the template on the left below and just copy and paste it into the box.

Template
What is the customer's situation: What support does the customer need: Is permanent or temporary support needed (For temporary support, please confirm an expected end date): Has the customer consented for this information to be provided:

Template

What is the customer's situation:

What support does the customer need:

Is permanent or temporary support needed (For temporary support, please confirm an expected end date):

Has the customer consented for this information to be provided:

Example
What is the customer's situation: Mr James has difficulty understanding finances, particularly complex scenarios. This can impact his confidence in decision making. What support does the customer need: Mr James will require additional information and explanation when discussing his mortgage and making any future changes. Is permanent or temporary support needed (For temporary support, please confirm an expected end date): Permanent Has the customer consented for this information to be provided: Yes

Example

What is the customer's situation: Mr James has difficulty understanding finances, particularly complex scenarios. This can impact his confidence in decision making.

What support does the customer need: Mr James will require additional information and explanation when discussing his mortgage and making any future changes.

Is permanent or temporary support needed (For temporary support, please confirm an expected end date): Permanent

Has the customer consented for this information to be provided: Yes

Case studies

Please note circumstances are assessed to individual customer need.

Mr Jones:

Mr Jones is a first time buyer and has not taken any form of mortgage finance before so is taking advice from a broker as he is unfamiliar with this home buying process. The broker will be the sole contact through the application however, the broker contacted TSB to say that Mr Jones may require additional help once his mortgage completes.

Actions TSB have taken:
- TSB explained our contact strategy to support the customer in the first 6 months and advised that, when the mortgage completes and if Mr Jones feels they need further support, we could log a temporary vulnerability for the first 6 months and support him in setting up the TSB app to track his mortgage.
- Broker decided on no further action at this stage but would ask the customer to register himself if help was required.
Mr & Mrs Smith:

Mr Smith has been in a hospice for almost 3 years with a grade 4 brain tumour. He was initially given 6 months to live. He has fluctuating capacity which means Power of Attorney can’t be obtained. Mrs Smith has been speaking to TSB and was advised to apply for Temporary Interest Only through the Mortgage Charter. Mr Smith was unable to sign documentation to give his authority due to his fluctuating capacity.

Actions TSB has taken:
- We have recorded the customer’s vulnerability and agreed Temporary Interest Only effective, subject to receiving a signed declaration from Mrs Smith only. (A Rate Switch can be done separately at maturity, on one signature if circumstances remain unchanged.)
- We are considering the customer’s request for a term extension, but need additional information, with the Temporary Interest only the priority.
Mrs Archer:

Mrs Archer has a visual impairment which impacts her ability to read information documents in our standard font size. Mrs Archer is completing a Remortgage application on their property and is concerned that they’ll be unable to read and understand their mortgage offer and other important documents during the application process. Mrs Archer has spoken to her broker who has passed this information on to the TSB Application Support Team.

Actions TSB have taken:
- During the mortgage application process, we can ensure all mortgage documentation and correspondence that are sent to Mrs Archer are in a format that supports their visual impairment, for example large print, coloured paper or braille.

Examples of TSB’s support

These pages on our retail website show you the types of support we offer to vulnerable customers and how we talk to them.

For more information and guidance download the FCA’s guidance for firms on fair treatment.

Money worries

Customers can talk to us if they’re worried about money or if they’re struggling with something specific.

Find out more

Vulnerable customers

Extra support for the customer if living with a disability, facing a serious life challenge or struggling to make ends meet. We have several ways to provide them with additional support.

Find out more

External support

For a list of charities that may be helpful for your customers.

Find out more

Additional borrowing

Anyone taking out a loan or mortgage should fully understand what it means and do it of their own free will.

Find out more