Support for our Armed Forces community

On this day, Armistice Day, it feels particularly poignant for us at the VRS to pay tribute to the selfless and heroic role that our veterans have played in keeping our country safe. We value the sacrifices that have been made, and remain constantly grateful for their contribution to our security. The VRS believes that veterans should be supported in every way necessary in recognition of this, and hope that the voluntary register, which is free to sign up to, can be one route to achieving this support.

We are aware that there are a number of veterans who struggle with financial vulnerability, or mental or physical health issues which may also impact on their financial affairs. For example, the Defence Select Committee published a report last year which said that cuurent research suggests that the number of veterans with mental health conditions that require professional help could be around 10%.

For this reason, we are honoured to be working alongside Veterans’ Gateway, a fantastic organisation that provides a first point of contact for veterans seeking support, and hope that the service we offer will be able to be of use for some of the people that they advise. Veterans’ Gateway have reported that finance is continually in the top three areas of need, though frequently in combination with another issue, for those using their service. Members of the Armed Forces community can encounter many of the same financial issues as the general population, for non-Service related reasons, but Service life, often starting in very early adulthood, can leave them uniquely financially underprepared.

A recent government consultation, The Strategy for our Veterans, spoke of the need for improved collaboration between organisations in order to offer veterans coherent support, which is the essence of what the VRS are hoping to do. It noted that veterans receiving support from many different organisations often have to repeat their circumstances and historic experiences to each new provider, which can be frustrating for the individual and inefficient for the organisations concerned.

If you know a Veteran who might benefit from contact with the Veterans’ Gateway, or the service that the VRS provide to support the financially vulnerable, we would strongly encourage you to put them in touch. Details about contacting the VRS can be found here.

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VRS Power of Attorney

Planning ahead with a Power of Attorney: don’t wait until it is too late

No one wants to think about what would happen if they lost mental capacity and could no longer manage their affairs. But many people don’t realise that if you don’t appoint someone to have power of attorney when you are mentally and physically capable to do so, it could potentially mean a complete stranger will one day make decisions regarding your future. At best, your preferred representative will have a more complicated and time-consuming struggle to ensure that they can take responsibility for making decisions in your best interests. One of the most common misconceptions around this area is that people assume there is an automatic right for their spouse, or next of kin, to make decisions on their behalf, and deal with their bank accounts and pensions for example, if they are no longer able to do so, but this is not the case.

Everyone knows that we should write a Will, but too few people know that it is also important to consider a Lasting Power of Attorney (LPA). This means choosing another individual, who can be anyone you believe to be appropriate, and giving them the legal authority to look after specific aspects of your financial affairs, or health and welfare, should you lose the capacity to do so. It ensures that even with a mentally debilitating illness, you can feel that you are keeping control by being the person to decide who will take future decisions for you.

It is a depressing statistic, but one that we all need to bear in mind, that by 2025 more than one million people in the UK will have dementia, according to the Alzheimer’s Society. One in five people over 85 already suffers from it, and apparently one person in the UK develops dementia every three minutes. In situations like this, handling your financial affairs becomes impossible, and you need to have decided upon the best person to take decisions on your behalf before it is too late to do so and you are deemed mentally incapacitated.

For, should you fail to do so and there come a time in the future when you don’t have the ability to make or communicate your own decisions, but you haven’t created a LPA, it may be necessary for the Court of Protection to become involved, as only a mentally competent individual can appoint a Power of Attorney for themselves. If you have not done so in time, then the Court can appoint someone to be your deputy, but their powers are very limited compared to someone who has Power of Attorney, it takes time for this to be processed, and there is an annual cost to renew a deputyship.

Once someone holds a Power of Attorney, the VRS are on hand to help them with alerting financial institutions to the circumstances of the individual as and when required, to ensure they are treated appropriately. You can read more information on our website about the process, and the various steps to take, here.

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A secure point of reference for vulnerable consumers and organisations they deal with

CCR magazine have an article this month about the VRS and the success of the recent launch event, as well as flagging the polling conducted by ComRes. The article describes the register as a ‘secure point of reference for vulnerable customers ‘, and notes that the VRS gives organisations dealing with vulnerable people a tool to help them meet their regulatory and ethical obligations in dealing with vulnerable consumers and to make the best possible decisions while doing so. You can read the article in full on p9 here: http://www.ccrmagazine.com/magazine/october-2019/.

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VRS evidence to the Lords Gambling Industry Committee

The House of Lords Gambling Industry Committee was appointed in June 2019 to consider the social and economic impact of the gambling industry. They published a call for evidence to look at how effective the current gambling act is at protecting vulnerable people from being harmed by gambling, and whether sufficient services are available for the support of people who are harmed by gambling, among other issues. The VRS responded to this call for evidence, and, among with other stakeholders, their submission has recently been published and can be read here. The Committee is now considering the evidence it has received, and is due to report by 31 March 2020.

The VRS submission looks at the way in which the VRS can work with in partnership with the ‘GAMSTOP’ initiative to help gambling companies identify vulnerable consumers and support them appropriately. It suggests that this could include a closed user group for online gambling companies and their clients, should that be considered a preferable way forward.

The VRS will follow the progress of the Committee with interest, and look forward to receiving the recommendations.

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Synectics partnership is a significant step in the VRS story

The news last week that Synectics Solutions was partnering with the VRS, and would be using the register to allow their clients to conduct vulnerability searches, was a huge boost to the VRS and a sign of the speed at which the VRS is starting to grow and receive recognition from the largest corporates in the data management space.

Synectics Solutions is one of the UK’s biggest data management and software development companies, providing financial crime, fraud prevention and information analysis services. For almost a quarter of a century they have led the technological revolution in and around sharing data and data syndication, and have given data-led intelligence to their global customers to allow them to make informed decisions. The fact that the register now sits within their solutions that their clients can access means that the reach of the VRS extends to a far larger range of organisations, ranging from the best known banks through to the biggest insurance companies and everything in between.

They pride themselves on being incredibly successful in reducing risk, combating fraud and financial crime and enabling public and private sector organisations to meet their regulatory commitments, and we are delighted that they have made the decision to work with the VRS. They are of the view that the VRS enables Synectics to evolve appropriately to meet the increasing need to recognise vulnerability, and allows them to provide the best possible solutions to help businesses treat customers fairly and compassionately.

We would encourage other like-minded organisations to work with us to really help transform the quality of life and peace of mind of vulnerable customers.

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1 October 2019 (London, UK) – Not-for-profit initiative, the Vulnerability Registration Service, today announces a partnership with Synectics Solutions, one of the UK’s leading data management and software providers, with the aim of helping to protect vulnerable consumers from financial harm.

The issue of consumer vulnerability is one that is being treated with increasing prominence by the financial services sector, partly as a result of the Financial Conduct Authority’s (FCA) focus on the subject in recent years. There is recognition that there needs to be greater consistency across the sector in dealing with vulnerability, and the Synectics and VRS partnership will help to achieve this.

The VRS and Synectics share the view that all organisations have a social, moral and regulatory responsibility to identify vulnerable customers. Many businesses will have invested in systems which help them to deal with vulnerable consumers, but there has until now been no single point of reference to ensure all parties have the information they need without consumers repeating the same difficult conversations over and over again.

With this in mind, the VRS was set up to enable organisations to identify those registered on the VRS as vulnerable customers at the point of application or when deciding on customer engagement strategies. When organisations are aware of a vulnerable person’s circumstances, they are better able to treat them appropriately. The VRS provides businesses with the decision-agnostic platform they need to understand more about who they are dealing with at a given point in time, helping them to ensure that vulnerable consumers do not find themselves in financial hardship with which they may struggle to cope. The register is seeing increasing momentum across multiple sectors, such as consumer finance, energy, water, mobile phones, insurance services and local authorities.

James Brown, Finance Product Manager at Synectics said “Synectics looks forward to working closely with the VRS to support vulnerable consumers. Synectics is committed to protecting the best interests of this wide and diverse group, and the VRS will help to allow greater industry wide collaboration and agreement on various treatment strategies offered, which is key to achieving this.”

Helen Lord, Director of the VRS said “The partnership with Synectics is a very significant step in the progress of the VRS, and reflects the level of interest that we have seen in the register since its launch in September. We are delighted that Synectics has chosen to work with us and recognises the benefits that this initiative can bring to help businesses treat their customers fairly and compassionately. We urge other like-minded organisations to work with us to really help transform the quality of life and peace of mind of vulnerable customers”.


Notes to editors

About the Vulnerability Registration Service (‘VRS’)

The VRS is a not-for-profit company limited by guarantee and has been developed following constructive dialogue with industry and consumer stakeholders. The VRS has an Advisory Board of experts to help provide thought leadership whilst it continues to develop the service. The purpose of the VRS is to empower vulnerable consumers, allowing them either to self-exclude themselves from credit and financial promotions or to slow down the credit application process. It provides a single reference point for consumers and organisations participating in the register, enabling an individual’s vulnerability issues to be handled sensitively and professionally by credit providers. It does not claim to provide information on all credit users, but crucially helps lenders to identify the most vulnerable consumers, and meet their responsibilities towards this section of the population, a growing issue for the industry.


Frequently asked questions about the VRS


What is the Vulnerability Registration Service / VRS?

The VRS is the UK’s first centralised registration tool to help people experiencing vulnerability ensure that their circumstances are taken into account by lenders and other organisations with whom they interact.


Does it cost anything to register with the VRS?

No, registration with the VRS is free for vulnerable people. The VRS is a not-for-profit company limited by guarantee – it does not charge vulnerable people to use its service and it never will, and all revenues from business users are used to maintain and improve the service we provide.


How many consumers are there currently registered with the VRS?

The VRS is already approaching 10,000 consumers registered to its service. Given the relative speed with which this number of users have registered with the VRS, even before its public launch, we would expect participation to grow significantly over the coming months.


What information does the VRS record?

Typically, all that goes on the register is a name, address, date of birth and contact details. We don’t record the reasons behind a registration. The VRS operates via a simple flagging system: vulnerable users can opt either to be pre-declined for certain services, or request that the organisations they deal with contact them about their registration before making a decision that relates to them.


How do you establish consent from vulnerable people to be on the register?

Membership of the VRS is entirely voluntary – users sign up for an initial period of three months, after which time they can require us to remove their details if they feel their circumstances have sufficiently improved.

Where a vulnerable person may be unable to register themselves, for instance if they are incapacitated or suffering from dementia, they may be added to the VRS by someone with a legal right to represent them such as power of attorney.


When a user registers with the VRS, who has access to their data?

Only organisations signed up to the VRS with whom the registered user has a relationship will be able to see any information – including that the user is registered at all – and only then when there is a specific decision to be made relating to that user.

Once a user has their details removed from the VRS there will be no searchable trace that they were ever registered. The VRS is completely independent of the credit reference agencies and does not share any information with them.


Does being registered with the VRS affect your credit rating?

Being registered on the VRS should never affect your credit rating.


Is information stored on the VRS secure?

The VRS takes the security of user data extremely seriously and uses the equivalent security systems as are used in online banking.


For media enquiries please contact:

Fraser Schurer-Lewis, Acuitas Communications

+44 (0)7961 027 281 / +44 (0)20 3687 0869


Catriona Foyle, Acuitas Communications

+44 (0)7720 998 313 / +44 (0)20 3687 0868


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More action needed from the gambling industry

It is an issue that continues to rear its head, and an area where it seems that far more could be done to support vulnerable consumers. A BBC News article this week explores the extent to which gambling is still big business in the UK. According to the industry regulator, the Gambling Commission, around £14.5bn was spent in Great Britain on gambling between October 2017 and September 2018.

Whilst most people aim to gamble safely, the Royal College of Psychiatrists said that gambling is a problem for about nine people in every 1,000, equalling about 1% of the population. The founder of the NHS National Gambling Clinic, Henrietta Bowden-Jones, says that problem gambling can lead people into debt, and describes gambling disorder as “a total loss of control” of how much you spend on gambling, with GamCare, who attended the recent launch of VRS, saying that they had seen an increase in enquiries, taking just under 30,000 calls in the 2017-18 financial year.

The VRS want to enable those people to take back control, should they choose to do so, through their self-registration system, and to support the gambling industry to act in a socially responsible way towards their customers. It would allow people to feel that they are having trouble controlling their gambling to ask for greater protections, and potentially to stop them from opening and using duplicate accounts.

In a recent survey conducted by ComRes on behalf of the VRS in September, the gambling industry was the second most mentioned industry by the public, out of a list of business types, when asked which business types need to do more to identify vulnerable customers, with 57% of respondents mentioning them. It is clearly therefore, an area where the public believe more action needs to be taken, and are wanting to see some urgent progress from industry leaders.

There needs to be a wider recognition within the industry that there are vulnerable individuals who may not be able to make an informed decision about gambling, and need to be treated accordingly in any communication with them. The VRS stands ready to work with more members of the gambling industry. The VRS service is provided free to those that register and the VRS service is a not for profit organistion. If you think that this would be beneficial for your business, you can learn more about the VRS and how to register here.

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The VRS was formally unveiled on Wednesday 11 September at an extremely well attended event in central London, at the Royal Society. There was standing room only at the event, with the audience made up of senior decision-makers from financial services, utilities, the third sector and other relevant bodies.

Attendees heard insightful and thought-provoking speeches from Paul Lewis; the CEO of the Consumer Credit Trade Association, Greg Stevens; Director of the Debt Managers Standards Association, Kevin Still; and Director of Christians Against Poverty, Dawn Stobart, following an introduction from Tony Leach, Director of VRS. They also watched a moving video with examples of consumers already signed up to and benefiting from the VRS: https://www.youtube.com/watch?v=NBr-4R9RpEs.

At the launch, the VRS published new survey data, commissioned from ComRes (fieldwork: 4-6 September 2019; sample: 2,009 GB adults), that clearly demonstrates the need for the kind of support the VRS tool provides, and the public desire for more significant action to be taken by businesses. The survey found that two in five GB adults have experienced a life event that left them feeling vulnerable, either financially or socially. It showed that:

  • 54% of the public think businesses definitely or probably should be required to identify whether a prospective customer is vulnerable in order that they can be better protected against harm; and
  • 50% of the public believe that businesses should have more regulatory requirements on them to identify vulnerable consumers.

The survey found that currently only 15% of the public agree that businesses do enough to protect their vulnerable customers. Payday lenders and gambling companies were particularly identified as business types that should do more to identify vulnerable customers, with 58% and 57% respectively mentioning them.

The positive response and feedback received from attendees was hugely encouraging, demonstrating that industry members clearly can see the benefits that this initiative can bring to help vulnerable consumers be treated fairly and compassionately.

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Vulnerability and gambling: the need for preventative action

The relationship between vulnerability and gambling is a particularly difficult one, which requires careful thought amongst all involved – and the reasons for this have been much in the news lately. Figures from earlier this month, for instance, show that the number of people suffering from gambling addiction being admitted to NHS hospitals in England has grown by more than a quarter over the last year, with 335 people treated for gambling-related problems in 2018.

In addition to this, a study by the Gambling Commission found last month that there are alarming links between problem gambling and suicide, with 5 per cent of gambling addicts stating they had made at least one attempt on their own lives. There’s been a steep rise too in the number of complaints against British betting firms, again according to the Gambling Commission, with a record 8,226 made last year – a striking 5,000% rise since 2013, when that number stood at 169.

It’s not simply down to how the gambling firms themselves have been behaving over that time, though – it’s a more complex picture than that. The gambling industry has grown enormously over the period since 2007, when restrictions on betting and advertising were relaxed – so there’s been a lot more betting around which complaints might centre, with gamblers losing a record £14.5 billion in 2018, almost twice as when the regulatory changes came a decade previously.

Neil McArthur, Chief Executive of the Gambling Commission, says that the increase in complaints is actually, in part at least, a positive sign that the public expects greater responsibility from gambling firms. “We are pushing the industry to know its customers, and part of this is actually, possibly, a good sign because it’s suggesting that consumers are demanding more of the gambling operators. And I would encourage them to continue to do that,” he explains.

And there are welcome signs that these growing expectations are yielding positive results. Mounting concern over vulnerable gamblers has helped spur action by the gambling industry itself to fund addiction treatment – the owners of several major firms have pledged to increase their voluntary levy on gambling profits from 0.1% to 1% up to 2023, a total contribution of £60 million.

More, however, needs to be done in the face of such alarming figures as those we’ve seen this month – and we need preventative action, as well as reactive tools like addiction treatment. The charity Gambling with Lives, which aims to support families bereaved by gambling-related suicides and raise awareness of the potential for harm, estimates that there are at least 250 gambling related suicides occur every year – and calls for self-exclusion software to be available online.

This is the Vulnerability Registration Service in a nutshell. We make no charge to vulnerable people signing up to make their circumstances known to organisations like gambling companies, and we never will. As a not-for-profit company limited by guarantee, all revenues are spent on ensuring that people experiencing vulnerability can opt out of situations which may only make matters worse.

GamCare, the charity which runs the National Gambling Helpline, said of the Gambling Commission’s latest figures that “it is important people seek help as early as possible”, and we couldn’t agree more. We’re ready to play our part to help those who need it at a moment’s notice, and look forward to doing so following our launch on 11 September.

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Welcome guidance on fair treatment of the vulnerable consumer

The VRS welcomes the recent announcement by the Financial Conduct Authority, of its renewed commitment to help the vulnerable protect themselves from financial harm – on this occasion, with a new consultation on guidelines for firms dealing with vulnerable consumers. The guidance does not so much provide a checklist of required actions as various options for ways to comply with the principles set out – a flexible approach which recognises the variety of organisations who deal with the vulnerable, and one which we hope will encourage the improved outcomes we all want.

The FCA has not stinted in its expectations, however, and rightly so – indeed the paper makes plain that not only is more action needed, but that improved results must be demonstrable. “Ultimately,” the paper explains, “we want to see firms doing the right thing for vulnerable consumers, and embedding this in their culture.” That means they need “to be more focused on ensuring that the outcomes experienced by vulnerable consumers are at least as good as those of other consumers.” It’s an ambitious goal, as those working to improve treatment of vulnerable consumers know all too well, but it’s one to be celebrated.

So what does it look like in practice?

The guidelines are clear that consumers need to be confident they are dealing with firms where the fair treatment of customers is central to their corporate culture. In part, that means they must be provided with clear information and kept appropriately informed before, during and after the point of sale – and, when they do receive advice, it should take appropriate account of their circumstances. This is the VRS’ reason for being: we’re here not to try and make decisions for vulnerable consumers or the commercial organisations they interact with, but to encourage better decision-making by ensuring they have appropriate knowledge of who they’re dealing with. If we can help firms looking to meet their social obligations in this way, we’re only an email or phone call away.

As the FCA consultation sets out, it’s also essential that consumers don’t face unreasonable post-sale barriers if they want to change products, switch provider, submit a claim or make a complaint. This is especially important for the vulnerable, because where an act of financial self-harm has been undertaken by a vulnerable person and identified in good time, there ought to be a straightforward route to having it rectified – and if lenders and creditors don’t already have such mechanisms in place, it’s only right they should heed this reminder. If those unfortunate decisions can be avoided in the first place, there’s less need to go down that road.

The VRS agrees with the FCA that there are many different drivers of vulnerability, many of which can place people at risk of problem debt or other forms of financial harm. The FCA 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”. We don’t attempt to define vulnerability at all – we tend to think vulnerable people and their carers are the best judges of that, and leave it to them to register with the VRS as they see fit. Vulnerable people are not always best identified at a glance by strangers – vulnerability is a more subtle condition than that, to which ultimately we are all susceptible. Vulnerable people are our friends, our family, and our neighbours – indeed they are all of us at some point in our lives – so let’s empower them to protect themselves when it comes to the potentially very serious distress of financial hardship.

It’s clear that plenty of firms already have policies and processes in place to ensure fair treatment of vulnerable consumers, and there’s been good progress made by some, to whom a good deal of credit is due. But in order to ensure they’re not doing less than they believe, they need to know who they’re dealing with at a given moment, and whether that person may be in a vulnerable condition – and we only know that by asking the vulnerable themselves whether they wish to make it known.

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