"Firms’ progress to-date has largely been limited to subjective individual assessments which risk inconsistency and complexity in recording."
The MorganAsh Resilience System (MARS) is designed to help both mortgage advisers and firms meet the FCA's requirements for understanding and managing consumer vulnerability. The FCA’s ‘Guidance for firms on the fair treatment of vulnerable customers’ came into force in February 2021 and will be strengthened by the ‘A new Consumer Duty’ paper, which is currently out for consultation.
MARS provides an objective measurement rating like the familiar credit score used by lenders across the UK. Aware of the potential stigma for an individual if labelled as vulnerable, MARS instead focuses on strengths – a person’s resilience. The system provides simple ratings which reflect every aspect of a person’s vulnerability or resilience, including health, wealth and life events.
The level of detail collected is tailored to both the stage of engagement and the potential for consumer detriment. For example, when a client is enquiring about a ‘low-risk’ product, such as life assurance, the level of detail required by MARS is minimal and may be provided by the consumer or their adviser. But for a high-risk or high-value product, such as mortgages and later life lending, a more diligent set of information would be used – with independent verification of that information.
Mortgage and financial advisers can input a client’s vulnerability information themselves. Alternatively, they can ask their client to complete an online questionnaire or, if the consumer is suspected to be vulnerable, can book an assessment of their client to be undertaken by a MorganAsh nurse.
The system can be used as a standalone tool or integrated with a firm’s CRM via secure API links. MARS is already integrated with systems from Intelliflo and Iress, with more integrations planned.
MARS is independent of both providers and products and can be used by anyone in financial services, for any product or service.
Andrew Gething, managing director at MorganAsh, said: “Just as a credit score is used to simply communicate wealth, MARS is used to communicate health and resilience. By using MARS, advisers and firms can simply enter their client’s details, and the tool does the rest. This enables them to focus on what they do best – delivering the best advice.”
Robert Sinclair, chief executive at Association of Mortgage Intermediaries, commented: “To meet vulnerability and impending consumer duty requirements, firms need to understand the characteristics of their customers – and be able to manage and report the conduct risk. Firms’ progress to-date has largely been limited to subjective individual assessments which risk inconsistency and complexity in recording. A move to more structured assessments that can provide consistent and objective data will provide management information that firms can utilise. The resilience rating within the MARS tool would appear to be a positive first step.”
Keith Richards, chair of the Financial Vulnerability Task Force, added: “Given the often complex and technical nature of financial planning – which automatically places most people in a position of vulnerability because of knowledge and experience-based dependency – we must do what we can, at every opportunity, to demonstrate and be seen as a trusted ‘safe pair of hands’. The current regulatory focus on vulnerability provides a timely opportunity to improve how we can recognise and address vulnerable circumstances, whilst also demonstrating individual care and empathy. Good practice principles and the use of fintech, such as the MorganAsh MARS tool, can greatly improve our ability to assess, store and communicate vulnerability across and between organisations.”