How much value do you place on Vulnerability within collections strategy

At this time of year lenders will be gearing up to handle increased levels of borrower contact and the smarter lenders will be preparing for proactive contact. In recent years there have been big advances in the ability to use technology and data to develop pre-impairment indicators that can help identify signs of potential borrower strain before a payment has been missed. There is speech recognition software that can help identify a vulnerable consumer through trigger words and voice tone. All very admirable, and all tools available to help protect a customer from detriment and especially those customers that are vulnerable and should certainly be encouraged.

However, whilst most firms and organisations are trying to improve the situation for vulnerable consumers it is usually after the event of credit or products being provided. My brother Nigel and I have been involved in consumer credit activities for over 35 years and have practical experience in doorstep lending, short term lending, payday lending, debt collecting and our current business as debt purchasers. We have sat on numerous committees and boards of consumer credit trade associations and regularly attend consumer credit roundtables and workshops and it became apparent to us that whilst most firms identify and do their best to deal with vulnerable consumers after the event of credit or services being provided it seemed obvious why was help to identify vulnerable consumers not being done before credit or services are provided? Having looked into the matter further it was simple in that there was nothing to check against, there was no register of vulnerable consumers.

Of course, considering vulnerable consumers circumstances before credit or services are provided is a change to what is currently offered, but sometimes change is for the better. From our many years of working with all types of consumers, it is usually vulnerable consumers that will require additional resource and time spent in providing help and assistance and in many cases, it is abundantly clear that the credit or service provided was not suitable.

In my role as Compliance Directors of SLL Capital Limited, I see the despair of those issued credit when credit was not suitable, and services sold when it is clear the consumer did not require the service. I see cases of those that go on manic spending sprees, gamble with no control and all too often cases of partner fraud and sometimes just poor decision making especially if the consumers native language is not English. In fact, there are so many examples of vulnerability that we always revert to the FCA’s original definition of vulnerability from occasional paper No 8 which defines a vulnerable consumer as: “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”.

You may be wondering if we can see the problem what are we doing about it? My brother and I have got together with a group of five like-minded individuals and formed a company called the Vulnerable Registration Service (VRS). The VRS is the only national register of vulnerable consumers. Our board consists of GDPR experts, Customer relationship management system IT experts, Credit Bureau data experts and business operational experts. The VRS also has an Advisory Board of recognised consumer credit experts that help to guide, innovate and challenge the VRS and feedback recommendations to the VRS Board.

The VRS is funded entirely by the stakeholders who all have a passion to try and improve the situation of vulnerable consumers and who’s mandate is to share a proportion of profit with those charities that help support the VRS and consumer database.

We genuinely hope that the lending community and in fact every organisation and service provider that genuinely wish to raise the game in helping to improve their business service to vulnerable consumers will use the VRS and its database of vulnerable consumers. Getting it right in today’s business place has never been more important. Getting it wrong could mean redress, company embarrassment and the regulator rightly looking at what you do.

Mark Bryant, Director at the Vulnerability Registration Service

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BUDGET NEWS – Extending debt Breathing Space

In last week’s budget the Chancellor announced that The Breathing Space Initiative is being extended from 6 weeks to sixty days which equates to about eight and a half weeks.

This scheme aims to give creditors a period of time free from fees, charges and collections activity while they are seeking debt advice and getting a solution in place before additional charges are introduced. It is hoped that this will reduce the stress that is encountered at this time and enable creditors to better manage their affairs.

This is a very welcome step and has been welcomed by many organisations that support vulnerable consumers especially those people with mental health problems who need more support at this sensitive time.

However, there is a general view that eight and a half weeks is still not sufficient time to allow consumers to get their debt management plans in place.
We at the Vulnerability Registration Service certainly welcome this extension to the Breathing Space Initiative and will be continuing our discussions with the Treasury to review how we can support its implementation next year.

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The National Audit Office Report

The National Audit Office” report out on 6 September 2018 says that there are 8.3 million people struggling with personal debt in the UK, other worry factors include:

  • 40% proportion of reported debt problems in 2017-18 relating to debts owed to government, up from 21% in 2011-12
  • £15 billion total outstanding mortgage arrears in 2018
  • £18 billion the NAO estimates of personal debt owed to government, utility companies, landlords and housing associations;
  • 4 in 10 estimated proportion of people in the UK who cannot manage their money well day to day
  • 5,000 approximate number of consumer credit lenders regulated by the Financial Conduct Authority
  • 600,000 estimated number of people who need debt advice but are unable to access it

The NAO goes on to say that evidence shows that good debt collection practice both benefits individuals and boosts collection rates. Common best practice principles include timely assessments of vulnerabilities, affordable repayment plans, and signposting or referring people to debt advice.

To read more follow link:

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VRS – News letter September 2018

Keeping you informed about recent events and developments within the VRS and how we are helping vulnerable people to make organisations aware of their circumstances.

As the Vulnerability database builds in volume, we thought it would be useful to check out where the most registrations were coming from in the UK. Hopefully, this will help organisations assess how registrations are relevant to their own customer-base, particularly if an organisation has a high proportion of customers in a specific region.

It remains free to load information to the Vulnerability Registration Service and if any company would like to conduct a pilot of using the service, please contact us.



Scotland 5% Northern Ireland 1% North East 3% North West 15% East Midland 28% West Midlands 15% Wales 2% South West 9% South East 14% Greater London 10%

Our Advisory Board

We are now extremely proud to have established our Advisory Board with a number of experts to help provide thought leadership while we continue to develop the Vulnerability Registration Service. Their wealth of experience combines an understanding of the commercial demands upon organisations while comprehending the importance of supporting individuals.

We are confident that the Board, in view of their broad experience, will help us to continue to develop a service that will help vulnerable individuals and the organisations who recognise the need to treat customers fairly. By sharing data between organisations and cross-sector, we believe the Vulnerability Registration Service will build to give an holistic view of vulnerability and streamline our ability to treat people in the right way and in a way that will minimise cost for companies.

James Jones

James is Experian’s Head of Consumer Affairs and leads the company’s public education programme guiding people on subjects such as credit reporting, credit scoring and identity fraud.

James regularly features on television and radio and in print and online media. He also runs an expert advice column on the Experian website and represents Experian at cross-industry forums. He is a director of the Money Advice Liaison Group (MALG).
James’ focus is upon supporting the consumer and enabling them to understand how their financial affairs will impact their lives.

Nick Pearson

Nick is regarded as one of the UK’s leading experts on personal debt having worked as a debt recovery consultant to several national financial institutions and served as a member of a wide variety of government task forces and advisory groups.
Nick is Head of External Relations at Gregory Pennington Limited, part of the Think Money Group. Previously, he was CEO of the Debt Counsellors Charitable Trust, having been appointed to set up the charity in 2014, and Director of External Affairs at the Paymex Group.
Nick was the National Debt Advice Coordinator at AdviceUK and Head of Debt Advice at the Citizens Advice office in London. He has worked as a specialist money/debt advisor and debt advice centre manager in organisations including a number of citizens advice bureaus, an independent advice centre, a students’ union and a local authority.

In addition, Nick has been a director and board member of the United Utilities Trust Fund, the Debt Managers Standards Association, Debt Resolution Forum and the Institute of Money Advisors. He has also been a member of the Financial Services Panel.

Anthony Sharp

The course of Anthony’s diverse career means that he can provide us with an invaluable amount of insight while we build our service. His experience means that he is sought after as lecturer and conference chair and to provide training.

Anthony has worked with Barclays International, the Church of England Children’s Society and the NSPCC as national fundraising organiser. He has held senior positions in the credit industry with Bentalls Plc and Asprey Plc and then joined the Consumer Credit Trade Association (CCTA) creating a long-running training operation. Much of this experience contributed to Anthony receiving the prestigious ‘Contribution to the Credit Industry’ award at the Credit Today Award Ceremony in May 2006.

Anthony was Chairman of the Central Region of the Civil Court Users Association (CCUA) for 19 years and now holds the position of Company Secretary for the CCUA. He was co-founder of the Money Advice Liaison Group and held the position of Chair for 29 years. He has held many distinguished positions in areas that are totally relevant to helping deal with vulnerability and made many contributions about how the issue should be addressed.
He was appointed as a member of the Bristol University Personal Finance Research on vulnerability and he is a member of the Money and Mental Health Policy Institute Advisory Board

Sue Wishart

Sue has extensive experience working in credit bureaus. She has strong commercial experience having had responsibility for the marketing of new services and databases to a variety of sectors. Sue also worked with many companies to enable them to use the Gone Away Information Network.

Sue worked as Head of Business Engagement for CIFAS, the UK’s largest cross-sector fraud sharing organisation, working with organisations to enable them to effectively utilise the CIFAS database to meet their business needs.

Sue’s experience has meant that she has a strong understanding about how data can be responsibly shared to effectively achieve the stated aims of any particular scheme and understand how to work with new sectors with various data sharing initiatives.

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19 Billion owed in everyday bills

£19 billion owed in everyday bills, as Citizens Advice reveals it helps 1 person every 3 minutes with bailiff issues

Citizens Advice is calling for better regulation of unaccountable bailiff firms as it reveals households have fallen behind on their essential bills, such as council tax and utilities, by an estimated £18.9 billion.
The Vulnerability Registration Service acknowledges the important advice and guidance that Citizens Advice provide to thousands of consumers with debt problems and would certainly agree that bailiff firms should be independently regulated to ensure that they conform with acceptable practices.

Of particular importance is that checks are made prior to any home visits in order to identify vulnerable consumers so that they are treated appropriately. Read More –

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Vulnerability in the Energy Sector

Vulnerable customers – do we need them, or do they need us?

It is clear that anyone who is vulnerable needs someone to help them. Is it as simple as offering those who are vulnerable some form of help? Or is that an oversimplification?

The question being pondered by Energy companies is exactly how to help. So, do we need them, or do they need us?

It is a deliberately provocative question that I hope will encourage some debate and thinking.

At The Vulnerability Registration Service (VRS) we are keen to learn more about the industries in which we work but also to share knowledge, insight and thought leadership. This paper is the first of a series in which we will look to share our expertise.

Ofgem the Energy industry regulator is concerned that the most vulnerable in society are also the most dis-engaged. Having no access to the internet, most likely to be pre-payment customer on a standard variable tariff i.e. the most expensive tariff provided by a supplier.

Ofgem estimate that over 4m customers will benefit from the safeguard tariff, with an extra 1m added from the Warm Home Discount scheme. They forecast that a further 2m will be added to the safeguard tariff in time for the winter of 2019.

All this builds up a picture of a growing issue in the Energy market, with more new companies joining the industry every month this adds to the challenge of vulnerable customers receiving a consistent level of service.

Whilst the industry has been instructed to protect pre-payment customers with a new tariff as well as the introduction of the debt assignment protocol (DAP) to encourage customers to switch to a better tariff the numbers switching still remain tiny compared to customers with a credit meter.

Some well-intentioned work but will it reduce the volumes of energy customers in fuel poverty. I think not.

With all the industry led initiatives and best practice at each business there is still so much more that can and should be done.

Everything we do at VRS is underpinned by intelligence and analytics. Whilst there is a great deal of reporting that exists on the topic of vulnerability there is more required in actual insight and what vulnerable customers think.

I noticed a discussion on Linkedin recently that asked:

“Should the energy industry define a joint approach without the need for the regulator to set out license conditions or principles and if so how do you do that effectively across a large and bureaucratic industry”?

There were a wide range of responses but most agreed that the regulator should not be needed to drive this action. Everyone recognised the scale of the challenge, there were a variety of ideas, but it was clear that the insight was thin on the ground, or at least those that took part of the discussion did not want to share any insight for fear that it would lose their business a competitive edge.

One industry expert said “Change within any industry is a challenge and usually takes quite a long time to implement. I do think this is the hardest part, I think perhaps enforcing the new policy could be tricky “

Another expert said “A complex issue where there is even disagreement on the definition of vulnerable. It comes up at every training session I do with collectors. “

So, in summary we all know this is a growing issue and there is no single solution, definition or experience for vulnerable customers. I could have rolled out more stats and comments from experts, but I really wanted to engage as many people as possible in working with me to do something different.

I want to leave you with a question and an offer to work together on something unique.

Is it true that vulnerable customers cost more to service than other customers, or in fact is it true that most vulnerable customers do not engage with the services made to help them? Maybe the truth is somewhere in between.

It is easy to get caught up in the edge cases and get convinced that these are the majority. I prefer to let the data do the talking.

To this end the VRS would welcome the opportunity to work with any business who is looking to understand more about vulnerable customers. This would form a cross industry research project that would allow us to understand more about how vulnerable customers take experience services from across industries. 

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Data sharing and vulnerable customers

In 2017 The Vulnerability Registration Service was approached by the Personal Finance Research Centre at The University of Bristol to take part in an expert interview to assist valuable research into the link between financial difficulty and mental wellbeing.

The research report was published in April 2018 in an article called “Sharing is caring? Could data sharing improve the support provided to customers in vulnerable situations?

This report asks whether the greater sharing of data between financial services firms could improve their ability to identify and support customers in vulnerable situations. It considers how such data-sharing could work in practice, and suggests things for the industry to consider if it is to take forward increased data-sharing.

You can read it here:  You’ll see that the VRS get a mention on pages 44,48 and 52.

There are also some other interesting articles addressing vulnerability here, including a document summarising the findings from a number of events held by The University in 2017. From these workshop events, it became clear that poor mental health, addictions and even suicide were all more likely where people experience financial difficulties. Look for “Financial difficulty and mental wellbeing – a summary of our 2017 workshop series”.

The VRS is a platform providing vulnerable consumers with a single reference point for recording their personal circumstances at a given point in time. An individual with manic spending, gambling problems or any other money issue can protect themselves by registering on the VRS register. If a registered vulnerable person goes on to apply for credit or services when their well-being is being compromised, the VRS will allow the user of the register (creditor/service provider) to take the appropriate action. As well as protecting the vulnerable, the VRS helps firms and service providers to make better, more informed decisions. Doing the right thing is not just a regulatory requirement, morally it’s a good thing.  
Any thoughts?  

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VRS – News Letter July 2018

Welcome to the latest Vulnerability Registration Service (VRS) Newsletter to keep you informed about recent events and developments within the VRS and how we are helping vulnerable people to make organisations aware of their circumstances.

“VRS is a new initiative to address vulnerability in an independent way but taking a cross-sector approach.
“We spend a great deal of time talking about vulnerable people, but now is the time to do something tangible and start to protect them.”

Sean Tyrer, Chief Executive Officer
The Money Carer Foundation.

While many of us are taking advantage of record temperatures, we think it is still important to be aware that many people are suffering from difficulties in their lives.  These may be life circumstances, financial problems, health issues or addictions and our objective is to be a one-stop shop to try and prevent people having to repeatedly contact organisations to make them aware of their situation.  

We believe vulnerability can affect people in many areas of their lives – these are likely to include how they deal with financial services or insurance companies, utilities or when they are contacted by charities, so we have aimed to provide a tool that can alert organisation on a cross-sector basis.

VRS is also intended to provide a tool for organisations to help them with their vulnerability strategy and meet their customers’ needs and the requirements of the regulators.  We are confident that we have developed a simple approach that should tick these boxes, particularly after communicating extensively with many sectors.  We have taken on board the views of many including regulators, such as the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office.  We have talked to many people working in utilities and spoken to Ofcom, Ofwat and Ofgem.  We’ve gauged the views of lenders, insurers, consumer groups and debt advisors.

What we are providing is the opportunity for individuals, or those with authority over individuals, to register with VRS in an easy way without the need to provide lengthy explanations about why they have done so.  Sometimes the registration may be permanent, but in many cases it may be that someone is in a temporary situation that they would like organisations to take account of when dealing with them.  If it is the latter, the individual can withdraw their consent about the registration at any time.


Signposting individuals to VRS

Individual registration to VRS is free.  What we try to do is work with organisations that are regularly dealing with vulnerable people and help us to give people the opportunity to register if they think it is appropriate.

One of the best ways of doing this is to include content on websites to signpost people to VRS.  Recently, we have been working with the Alzheimers’ Society and Carers Trust to ensure that the people who visit their websites are aware of the service.  

We believe that our work with these organisations is essential because they are often dealing with the most vulnerable people in society or their carers who will also be under huge pressure and need to protect those they look after.  Carers can register with VRS on another’s behalf where they have legal authority to do so – having a Power of Attorney, for example, enables people to register on somebody else’s behalf.

If somebody has dementia, for example, it may be that they are no longer able to look after their own affairs, whether that be financial or otherwise.  Those in care are often at risk of having their identities compromised – information about them may still be recorded at their previous address which is rich pickings for fraudsters.

Advisory Board

We feel it is essential to get independent views about the service we are providing so we now have an Advisory Board which consists of people with many years of experience, particularly in dealing with vulnerable consumers in the financial sector.  Our next Newsletter will give more information.

As a new initiative, we value your support. If you know of any organisation that may benefit from using the VRS service please feel free to forward on our VRS E-Newsletter.
For more information regarding the VRS please contact our VRS Directors: 

Bruce Turnbull
Phone: 01273 960 617

Tony Leach
Mob: 07885675045

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Monzosocial Media

You may have read our recent article on the VRS website about gambling (

The British gambling industry has ballooned in size over the past decade, thanks to the growth of online games and the liberalisation of gambling laws. The Gambling Act 2005, which came into force in 2007, opened the door to TV advertising for sports betting, online casinos and poker, giving betting companies direct access to people’s homes.

The industry’s income (as well as the amount of tax it pays to the Treasury) has soared since, according to figures from the Gambling Commission. These figures make pretty interesting reading. For example, the gross gambling yield (the amount gambling firms win from customers) was £8.36bn in the year beginning April 2008, shortly after the act came into force. From October 2016 to September 2017 the GGY stood at £13.9bn, and you can bet it will have increased by the time the next figures are published in November 2018 (no pun intended, by the way). There’s no denying that gambling is big business and the value of the global online gambling market will just keep growing.

Like many people, I’ll have a bet on the Grand National once a year but for others, it’s not that simple. Problem gambling is harmful to psychological and physical health. It can cause spiralling debt, distress, depression and other anxiety-related problems. As with other addictions the consequences of gambling can lead to feelings of helplessness, it can wreck relationships and in some cases it can lead to attempts at suicide.

For people struggling to limit their gambling, the most effective way to stop can be to self-exclude to stop them falling back into the habit if willpower alone doesn’t cut it. However, it’s currently not possible to self-exclude from all forms of gambling; even after excluding from one high street bookies people can still log on and gamble online, or go and find a casino. Self-excluding from a single type of gambling can require contacting numerous operators over the phone or in person, all of which can be particularly hard if you’re also struggling with your mental health.

That’s why we at the VRS were delighted to hear that Monzo have created a solution for this growing problem. Using a newly-designed app, account holders can now block themselves from making gambling transactions on their Monzo account, straight from the app. When the feature is turned on, any payments that an individual tries to make to gambling merchants (either online or in person) using their Monzo account are blocked. It will take a chat with the customer services team and a 48 hour “breather” before it can be turned back on. Monzo calls this ‘positive friction’ and it gives people the time and space to work out whether the decision to gamble again is the right one for them.

To read more about Monzo’s fantastic initiative, go to

The VRS is a platform providing vulnerable consumers with a single reference point for recording their personal circumstances at a given point in time. An individual with manic spending, gambling problems or any other money issue can protect themselves by registering on the VRS register. If a registered vulnerable person goes on to apply for credit or services when their well-being is being compromised, the VRS will allow the user of the register (creditor/service provider) to take the appropriate action. As well as protecting the vulnerable, the VRS helps firms and service providers to make better, more informed decisions. Doing the right thing is not just a regulatory requirement; morally it’s a good thing.  For more information go to

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VRS is a vehicle to help organisations

The Vulnerability Registration Service (VRS) is a vehicle to help organisations to protect vulnerable individuals should they apply for financial services or if their circumstances need highlighting when dealing with organisations with which they already have financial agreements. VRS has been developed having taken into consideration the high level of focus on vulnerability among decision-makers, regulators and media. VRS starts to address the concerns and issues that have been raised.

The Vulnerability Registration Service (‘VRS’) has been developed to help vulnerable consumers protect themselves against the financial, social and very personal hardship suffered as a result of debt and financial problems. The service is deliberately simple to use in that it does not provide details of the individual’s circumstances but allows organisations to treat them in the appropriate way helping the latter to meet their corporate and regulatory responsibilities, including TCF obligations. It is also an independent service which will easily complement other checks that businesses undertake as part of business as usual while maintaining focus on vulnerability, avoiding the risk of missing the need to deal with some individuals in a specialist way.

In summary:

1. The VRS provides an easy to use, secure, single point of reference for vulnerable consumers, lenders and other organisations – cross sector application.

2. The VRS is independent of other databases.

3. The VRS has been established by a team with a track record of success and innovation in their respective fields – consumer credit; business leadership;
compliance, regulatory and consumer affairs; and IT.

4. The VRS provides a valuable tool in meeting regulatory and social responsibilities towards vulnerable consumers.

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