• Our client, a top 10 UK mortgage lender, had been considering its overall approach to vulnerability since the publication of the FCA’s Occasional Paper 8.
  • Huntswood were engaged to support the delivery of the firm’s initial gap analysis and implement both tactical and strategic interventions to bring the firm in line with regulatory expectations in relation to vulnerability, and to ensure all of the firm’s customers were being treated fairly.
  • The firm was large and complex with many different brands, products, locations and customer access channels. Our overall aim was to make it easier for the customer to engage with our client.


  • We completed an initial gap analysis with our client and highlighted a series of areas for change. Together we focused our approach on 6 key life events including bereavement, redundancy, illness, divorce, third party carers and early arrears.
  • The first area of focus was the firm’s bereavement processes where a number of different approaches were being taken by the firm.
  • After conducting a review of the current arrangements, it was agreed that the programme should focus on the following three areas:
    1. Implementing a “Tell Us Once” strategy across the firm, to include all brands, products, locations and channels. This aligns to the BBA taskforce principles for vulnerability when a bereaved customer should only have to tell the organisation once about a death. This information is then circulated to all relevant stakeholders. Our solution was to have a method for informing its employees of deaths electronically. The staff were trained on what to do when such a notification was received. In addition, with our client, we decided to look at more advanced technology based solutions that would automatically update all systems. We are currently working with the firm to determine the best option
    2. Reviewing our client’s process of collecting outstanding debts. Before our engagement, the firm’s approach had been to write off debts without understanding whether they could be recovered. Following our investigation, we identified that our client had recently moved into a position where they could collect the arrears in a much more appropriate manner from customers’ estates in unsecured lending books. This approach has now been shared across the firm and is being considered for other products
    3. Considering with the firm whether a centralised team could be more effective or not. We were asked to provide the firm with an overview of their current operating models and present other options available. We are still currently reviewing these options with our client


  • The delivery of fair outcomes to customers in vulnerable situations is key to the strategic intent of our client and by working with Huntswood, the firm was able to improve the current situation for customers.
  • This project is still ongoing. However, our intervention has resulted in an enhanced customer experience where customers only have to tell the firm once about bereavement.
  • Furthermore, our guidance has provided our client with tangible commercial benefit as they are able to collect a larger volume of arrears post-death. Therefore, due to our engagement, the firm are more efficient and cost effective.