Identifying and supporting vulnerable customers

Welcome to our session today. I am Fiona Hanrahan, a Senior Technical Manager at Royal London, and I'm with Shelley Read, who's also a Technical Manager. And our session today is called Identifying and Supporting Vulnerable Customers. And Shelley and I like this session as it's a wee bit different and we get to work together.

Shelley works on the protection side, and I work on the pension side, so these opportunities don't always come about. So, in this session, we'll think about vulnerability in general, and then have a focus on what it means for both protection, which Shelley will cover, and pensions, which I'll cover. Now, if you're listening live and have any questions during the session, please use the online functionality to submit your question, and Shelley or I will get back to you as soon as possible via email.

And if you're listening again from the CPD hub and have a question, please get in touch with your usual Royal London contact. After listening to the webinar, whether that's live or play again, you'll be directed to a short quiz, and after this you'll be able to download your CPD certificate if you want one.

So, our objectives today are as follows: to have a better understanding of why it's important to identify a vulnerable customer. We will look at knowing how to recognise a vulnerable customer, we'll be up to date as far as we can with the FCA guidance on vulnerability, and we'll also know the support that providers can offer.

So, thinking about our agenda a bit further then, we'll go over the FCA definition of a vulnerable customer, and we'll have a think about why it's important that you understand a vulnerable customer. We will talk about how to identify a vulnerable customer and how you can support them both from a protection point of view and a pensions point of view.

So, let's get started then with that definition of vulnerable customer. And I'll say it's probably not as obvious as you think. As I'm sure you know, the FCA published its guidance for firms on the fair treatment of vulnerable customers in February 2021, and that was final guidance 21/1 if you want to know or go back and look at it.

And then they highlighted in their finalised guidance on Consumer Duty, what their expectations are or where in terms of monitoring the outcomes for consumers or customers with characteristics of vulnerability and those protected characteristics.

So, as a quick reminder of how the FCA define a vulnerable customer. A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. And the FCA's four drivers of vulnerability, do kind of make it easy to recognise the breadth of possible vulnerabilities, many of which we might recognise as having experienced ourselves.

And what it comes down to really is what we want you to appreciate is that anyone can be vulnerable at any time. And it's really important to note or remember that clients can be vulnerable at any time in their life, not just when they become elderly. And that was my default assumption when I started to look into this.

Someone could be vulnerable in their twenties or thirties due to many different factors, which we'll look at a little bit closer over the course of the webinar. And it's also really important to appreciate that vulnerability can be temporary, perhaps due to a life event or permanent, perhaps due to a disability.

And this vulnerability and the nature of that vulnerability can change over time. For example, a widow might become or be vulnerable following the premature death of their spouse, but over time become less vulnerable, but then a further life event such as another family death or redundancy or some other life event could cause that customer to be classed as vulnerable once again.

We will, over the course of the webinar look more closely at these different aspects, but I'm hoping you're already kind of gathering that we need to be vigilant to identify and then adapt our support for these clients or customers. So really then when we think about the FCA definition, you should think about vulnerability as a spectrum of risk and all customers are at risk of becoming vulnerable. And that risk is increased by characteristics of vulnerability related to those four FCA drivers. So, when we think about health or disability, we're thinking about health conditions or illnesses that affect someone's ability to carry out day-to-day tasks.

When we're talking about a life event, we're thinking about bereavement, a job loss or a relationship breakdown. When we talk about resilience, we're thinking about a low ability to withstand financial or emotional shocks. And finally, capability could be low knowledge of financial matters, or low confidence in managing money, that's financial capability. Low capability could also occur in other areas such as literacy or digital skills. And of course, identifying vulnerability can be difficult. Not all clients displaying these characteristics will be vulnerable or may not become so immediately or even want to disclose to you. So, firms need to be able to respond to these potential vulnerabilities as the client moves through that spectrum throughout their lifetime.

So, looking at each of these individually then. Health or disability key driver could relate to physical disabilities. It could be a severe or long-term illness. We could be talking about hearing or visual impairments, mental health challenges or disabilities that result in low mental capacity or cognitive issues. A life event could be unexpected or completely expected caring responsibilities, whether that's younger dependents or older dependents. It could be a bereavement, it could be an income shock such as a redundancy a loss of a job, or inability to work through illness. Shelley will definitely talk a bit more about that. It could be a separation or divorce or simply having something like non-standard requirements such as ex-offenders, care leavers, or refugees.

And when it comes to resilience, we're thinking about low or inconsistent income, being in debt, having low savings, a lack of support from family or friends, or simply low emotional resilience, such as somebody making impulsive financial decisions, and I'm sure we all know someone like that. And lastly, by capability we could mean learning difficulties, low English language skills, poor literacy or numeracy skills, a lack of digital skills. And lastly, low knowledge or confidence in managing financial matters.

So, we've talked about vulnerable customers, but why is it important that you understand them? And the first one I wanted to talk about is really the level of individuals that we're talking about. So, some of the more obvious points are that vulnerable customers might not be able to make the best decisions for themselves or represent their best interests, but what you might not appreciate is the percentage of the population showing one or more of the characteristics of vulnerability.

So, based on the latest FCA financial live survey, 49% of UK adults show one or more characteristics of vulnerability. 26% of UK adults have low financial resilience. And 61% of UK adults find keeping up with domestic bills and credit commitments a heavy burden or somewhat of a burden. So, I'm not sure if those percentages surprise you. I think they certainly did to me. And it's also worth saying that all of those statistics mentioned have increased since the previous survey.

So that's probably not unexpected, but quite sad, I think, at the same time. And keeping us up to date as well. In March 2025, the FCA published 'Delivering good outcomes' for customers in vulnerable circumstances. And in this, they set out their findings against the key expectations and requirements under the Consumer Duty.

As a reminder, these are governance and outcomes monitoring consumer support, consumer understanding, and products and services. And really what their intention here is that by publishing how firms are embedding the Consumer Duty, firms can learn from the good practice as well as the areas for improvement that they've identified.

And it's worth a reminder that if the FCA details areas of good practice, this is what you should be aspiring to if you're not already doing it. It's not just for information, in other words. So, we'll have a look then at the areas of good practice first and then the areas for improvement.

So, when it comes to effective use of data to monitor outcomes, a small number of firms used this data effectively to identify where customers in vulnerable circumstances were experiencing worse outcomes than others. So, it meant that not everybody was. They also saw examples of firms delivering flexible and tailored support, strengthened by training frontline staff on how to support customers with characteristics of vulnerability. They saw some firms take steps to review and improve the clarity of their messages to customers and provide these in a timely manner.

And finally, some firms incorporated feedback from lived experience panels and focus groups into their development processes. So, remember these areas of good practice, if you're not doing them already, this is what the FCA are certainly intending you to consider or incorporate if you don't already.

So now for those areas for improvement that they noticed. Most firms were unable to show how they effectively monitor and take action on vulnerable customer outcomes. Some firms failed to give appropriate support, such as opportunities to provide disclosure or train staff. They also saw examples of firms not providing appropriate or accessible channels to vulnerable customers.

And lastly, most firms could not identify how they embedded vulnerable customer training into their processes. So now I'm going to pass over to Shelley, who's going to take you through the next section. Thanks, Shelley.

That's great. Thanks Fiona.

So now we understand how important it is to ensure vulnerable clients are supported and any risks of a certain type of harm are minimised and making sure that we meet their needs. How do we actually identify a vulnerable client?

I think we all know, don't we? Sadly, we go through difficult times in our lives as demands and pressures change, and we all experience challenging times, but we don't always share this openly, and that's why it can be really tricky to spot if a customer needs any extra support.

So, it can be difficult to spot if customers do need that extra support. You may have clients who choose to disclose vulnerabilities directly, such as telling you that they're hard of hearing, so telephone conversations might be a bit tricky for them. Others may though divulge vulnerabilities indirectly. So, they might say that they're struggling to read, or they might say that they're just struggling to keep up or understand with the information that you are giving them. So, if we look at the next slide, there are some other signs to look out for. This isn't definitive, it's just some of the things that you might want to bear in mind.

So, asking unrelated questions can be a real sign that someone is vulnerable in the way that they may be not understanding, and repeating themselves, or appearing distressed or sounding flustered can also be a sign. As can constantly answering yes to questions, but really not appearing to be keeping up with your conversation. And making statements such as, my ‘partner has just died’, ‘my husband always dealt with these things for me’, or ‘I've recently lost my job’, or ‘I'm being, I'm really nervous about being victim to a host or a scam’ can be signs to look out for when we are looking at vulnerability. So, whether they're directly or indirectly disclosed to you, a client is unlikely to use that word, vulnerable or really to understand that they might actually be classed as vulnerable.

So, trying to talk to vulnerable clients about their difficulties without actually mentioning those words, I think is really important. So, using your internal data or maybe data that you work in partnership with, can, I think, really help you to identify customers that could be, not definitely, but could be at risk of vulnerability.

So, you can see on screen right now just a short list of some signals I think we should look out for: any late or missed premiums. Now this might not be the case of vulnerability, but it could show that someone has maybe lost their job, or they've misunderstood some information. Now a claim on a protection policy is almost always going to signal a time of vulnerability for those that are left behind, those that are bereaved. And as Fiona said a little earlier, that could be permanently for some people, or it could be temporary.

Now not attending a medical underwriting appointment, we know that lots of clients sometimes are nervous about going to a medical appointment of any sort, but when they're constantly cancelling those appointments and time is going on and on, it might be that they are really anxious about this situation and you might need to deal with them a little bit differently.

So, cancelling a protection policy, this could be a sign of vulnerability. As Fiona said, it could be a sign of financial vulnerability, maybe that they've lost their job, or maybe they are ill. So, this can be, really important data to use.

And increasing or decreasing contact with your client and out of character behaviour, probably put these two together, really. You'll know your clients really well, so if there's any change in behaviour, maybe they were often on the phone to you and now you haven't heard from them for months and months, or maybe suddenly they're starting to ask you an awful lot of questions, that might be a trigger to think that there's something going on in this person's life that might be making them vulnerable.

And of course, a family member claim is more than likely going to mean that your client is going to go through a time of vulnerability where you might need to change how you deal with them.

So, let's have a look at the next slide and look at providing opportunity for disclosure. So, I think, giving clients the opportunity to disclose any medical conditions or any additional needs throughout your relationship can really help that they constantly get the support that they need and asking if they're happy with you, sharing this information with a provider such as Royal London can make sure that their needs continue to be met. So, providing opportunity for disclosure, I think is really important. And I've just got three areas here. An initial client meeting, I think with new clients this gives you the opportunity to seek and really encourage disclosure of any vulnerability or support needs by asking for further information. And regular client reviews. We know by ensuring existing clients receive regular reviews, it gives you the chance to take note if there's been a change in either their personal or financial situation. So it might be that they've taken on a caring role, it might be that they've had a relationship breakdown, and they indeed are looking to be separated or divorced.

They could have been made redundant and lost their job for some reason, or as we've highlighted before in the last couple of slides, it could be due to their own illness, or illness of someone in the family, or a premature death of someone.

Now, client feedback surveys. I think these are a great idea and can really indicate if a client needs additional support or indeed might prefer to receive information in a different format, i.e. this could change, so if they become hard of hearing, they might now not want to liaise with you by telephone. So, asking about things like their communication preferences or any additional needs by means of a survey can not only unearth any vulnerabilities, but also demonstrate how you are looking to support vulnerable clients.

And all of the above can really help you, I think. If your normal advice process is still appropriate for those clients' needs, if the product that you've recommended is still suitable, and if the method of service delivery needs to be flexed at all to make sure that your clients are still getting the information that they need, and with a nod to Consumer Duty to make sure that we're avoiding foreseeable harm.

So, let's have a look on the next slide, how you can support a vulnerable customer. Before we look at some practical protection aspects, let's just take a minute to look at the financial resilience and remind ourselves exactly what this means. Well, you can see on the screen now that the Association of British Insurers say that financial resilience is the ability to withstand life events that can impact your income, and people's financial vulnerabilities are even further exposed when considering housing and day-to-day costs if they're no longer able to work. So, with this in mind, let's now have a look at some sort of practical protection aspects.

Now the role of protection advice. So, on the left-hand side here in the white boxes, you can see some real-life events that are definitely going to test someone's financial resilience. And as a result with our core subject today, put them in a vulnerable category. Now on the right-hand side are just a few examples of protection solutions that could avoid real financial stress for your client, and therefore to help the chance of them entering a period of vulnerability.

So from an avoiding foreseeable harm, from a financial aspect, it becomes even more important to have a real full, robust protection conversation helping you to review your customer's needs, making sure that they can continue to be fit for purpose, and are also flexible enough to the change as your client's life, their family, their housing, and their career change.

So, let's have a look now on the next slide. How can you support vulnerable clients? Well, there's a few things here that I think are important client fact finds. Now, these are going to expose any areas of vulnerability, and here you can find out directly which form of communication is going to be the most suitable for them. So, is it audio, is it face-to-face? Is it braille, for example? Now cancelled premiums as we said previously, can be, not always, but can be a sign of vulnerability, possibly a temporary one, but it certainly needs further investigation to see why those premiums haven't been paid.

Now, we mentioned it on the previous slide, but regular reviews are super, super important, I think, by ensuring existing clients have those regular reviews, you can then identify any changes to their personal or financial circumstances. And recording things on a client file. Again, I think this is so important that if you do identify a vulnerable client, it's very easy and obvious to someone else in your firm that has any dealings with them or picks up that file, whether it's a paper file or a digital one. So having a vulnerable client marker that's very obvious to other people in your firm I think is really, really important.

And signposting protection advice. Again, we looked a little while ago, didn't we, at some life events that can really test financial resilience and as a result, increase the risk of vulnerability. So, if it's not an area of advice you plan to have or have the resource to give them, please ensure that your client is pointed towards someone who can. And then again, this is going to decrease the chance of a client becoming vulnerable.

And finally, communication clarity. We've mentioned it a few times and it is really important to ensure that every single client, regardless of any vulnerability, receives the communication in a way that's really clear to them.

So, let's move on now and have a look at how can you spot and support a vulnerable customer. So having flexible processes I think is really important. Communication needs aren't just about how you deliver information to your clients in a written or spoken way. Also just give some consideration to where, when, and how you are giving information to them.

So, my next point, offering flexible meetings. To put a vulnerable customer at ease, I think you need to be flexible about where and when appointments are held. They might like to come to your office if you have one, or particularly if they are in poor health or have recently been bereaved, it might be more comfortable for them if you visited them at home.

And recognising trigger points. Understanding the factors that cause particular client behaviours can help you to spot a vulnerability and therefore to act accordingly. Fiona and I hope that this webinar will help you to recognise some of those points.

Now appointing a vulnerability champion within your firm, I think is really, really important. So that person can review and adapt your company's policy over time and create training so that all of your employees within your firm, all staff, are really up to date and can stay informed of how to deal with vulnerable clients.

And reviewing your onsite accessibility. This might sound really obvious but ensuring any client welcoming locations have ease of access, and it's very comfortable for anyone who has a disability to access your site.

Now reviewing and offering the right information at the right time, and importantly, reducing jargon and technical terms. This might be quite obvious to you, but they are things that we might overlook. It's really important, I think, when giving recommendations or advice that your clients understand what they're being given at each step of the journey. It includes understanding of any risks or benefits of the products you are recommending or the services that you are providing. And remember, if there's anything that they don't understand, you may have to explain things several times or maybe in a different way, such as case studies or illustrations.

And instructing a letter of authority means that your client has a record of the person or the people they trust to correspond on their behalf in the event they lose capacity to do so. For example, if they may be in hospital. So, the appointed third party in the letter of authority has authority to be given policy information or change adviser servicing rights assigned to that policy, but it's important to note they don't have authority to be able to make changes to a policy. That can only be done through a power of attorney. Which brings me onto that next.

There may come a time when your clients may no longer want or no longer be able to make financial decisions themselves, so setting up a power of attorney does enable them to give one or more trusted friends or family the legal authority to make decisions on their behalf. Now, these decisions can be about property, they can be about their finances, as well as health and welfare decisions should they become in a position where they can't make those decisions for themselves.

Now if we move on to the next slide. My work here at Royal London with vulnerable customers has drawn my attention to the real significant and growing issue of economic and financial abuse, not just in the UK but globally. So, if we look on the next slide, we've got some research here from a charity, ‘Surviving Economic Abuse’ that came out in 2024.

So, more women disclose economic abuse to financial service providers, in fact, 23% than to the police at only 13%. So, the reason I wanted to talk about this is that if you are an adviser, there's a very strong chance that you will come across a victim of this type of control. And generally, but not always, but generally, it is females that seem to suffer this type of control. One in five women in the UK, that's five and a half million, have experienced some level of economic abuse in the past year. So, you can see the likelihood of you meeting a female going through this sort of control is very strong. And one in three victim survivors have had to give up their home due to economic abuse and 78% of those survivors say joint mortgage abuse kept them sadly from leaving their home and escaping that form of control.

So, on the next slide, let's just have a look at exactly what is economic abuse. Now it is a legally recognised form of domestic abuse, and it's where one person controls or restricts access to, not just money, but resources and economic independence. So, it can include controlling finances, but also, and I must admit, I didn't really think about this when I started researching, but it also looks at controlling employment, transport, utilities, food, and even housing. It often does sadly occur alongside other forms of abuse, such as emotional, psychological, physical, or even sexual abuse. And it just diminishes the victim's capacities to support themselves, forcing them to depend on the abuser financially.

So, let's have a look at economic abuse and protection policies. So, this could mean, and these might be things an adviser you need to look out for and be mindful of, it can be coercion into taking out or even altering a policy, maybe increasing the amount of cover. It might even be as extreme as forging signatures or misrepresenting information. It might be that the abuser denies access or doesn't allow the victim to cancel or change a policy. Or it might be the abuser does actually cancel a policy that the victim certainly didn't want cancelling. And it can be that the policy is used as a threat or leverage, saying that in the event of death of the victim, that policy's going to pay out a huge amount of money to the abuser potentially.

And it could be that splitting a policy and future underwriting if someone is able to escape an abusive relationship could be really difficult and we are within a large group of providers looking at ways to make splitting a policy easier in this event.

We also need to look at future underwriting. The likelihood is if someone has been through this sort of severe abuse, they may well have had some mental health issues, and we need to be mindful of that when we're underwriting in the future.

So, on this next slide, we've highlighted some, but not all of the signs that someone may be a victim of this coercive control.

So it might be, and these are things that you can look out for, not just as an adviser, but maybe amongst friends and families that they don’t have enough money and they should have because of their job or role, et cetera. Or they might be asking to borrow money from you. It might be that they're always using cash and not a credit card, and they also seem to want to seek a partner's permission before spending anything. It might be that they're not socialising. It could be that they used to go out a lot with you as a friend or family, and now that's suddenly come to a stop. It might be that there's a change in appearance, a change in the way that they dress, or it could be that you notice that they're hiding purchases.

Now where joint finances are concerned, it could be that salary or benefits are paid into a partner's account, or no access to a joint account. And this is something, as an adviser, that you might see when you are setting up maybe a mortgage, or indeed a protection plan. It could be that you notice that someone wants to leave work or wants to bring to an end a career that they had previously seemed to really enjoy. And it may be that abusers take advantage of the cost-of-living crisis and make sure that there is even less finances available to the person under control.

What can you do? We've said it's more common than you think. What can you do if you suspect economic abuse is happening to a client or even maybe to friends or family?

I think it's important to express concern. Don't ask too many questions but say that you are there to listen. But it may be that the victim doesn't want to talk at this moment. But saying that you and help is available I think is really important. And maybe just as an adviser, now that we know how prevalent it is, having information about domestic abuse support to hand might be really important. So, you can encourage a female going through this to contact a helpline or online support. You could even offer to be with them when they call. And also providing training for staff to make sure they also can recognise these pointers and really signposting for further information. We are not expecting anyone to suddenly become a counsellor but knowing how to recognise those signs and where to signpost for more information, I think is really, really important.

So that brings me to the end of that topic of emotional, financial abuse. I'm going to pass back to Fiona now to look at some practical pension aspects.

Thank you so much, Shelley. I wanted to have a think about some practical aspects around vulnerability which are particularly relevant to pensions.

And when thinking about this, I sort of came up with three. Income drawdown, obviously as you get older and you're drawing your income, if you are vulnerable, then your income sustainability probably becomes even more important. Pensions and divorce are quite an obvious one. You could have a client who is perhaps losing part of their pension. Or you're the other side where the client is the ex-spouse who's receiving a pension credit, so we want to cover that. And lastly the taxation of death benefits and the changes around death benefits, particularly as a result of the budget in 2023. When it comes to income tax but also looking forward to those IHT changes. So, there we're not so much thinking about the member, we're thinking about you advising the beneficiary, the one who's left behind. So, they're already obviously in that vulnerable situation. And I would say key to that is making sure that you're up to date, at all possible, with the changes. And that's looking forward as well to those IHT changes.

So, income drawdown is the first one we'll start with. And in March 2024, the FCA published their findings after their thematic review of retirement income advice and vulnerable customers were mentioned a few times and the findings at that point stated that broadly there's some good news, but there's definitely room for improvement. And I think we saw that in the good and pure practice, even from this year. 952 out of 958 firms had put steps in place to identify vulnerability, but a small number only kind of had generic policies in place. And there were instances where potential vulnerabilities have not been identified, recorded, or explored, despite there being evidence on the file to suggest that vulnerabilities might be present.

So, clients into accumulation, income drawdown, where presumably most people's capacity to earn further income is reduced because you're likely retired. They're faced with that prospective income sustainability, and it's easy to see why a vulnerability at that point could lead to a greater detriment than it would while you're accumulating funds.

So, I wanted to show you the research methodology from the FCA and the results were drawn from a representative sample of 977 adviser firms. And they had responded to a data survey, but there was also a desk-based review of advice models and there was a hundred firms responded to that.

So remember this was the first time since pension freedoms were introduced that the FCA had looked at or told us what good and bad looks like for retirement income advice, and the data survey indicated most firms had or had made reasonable adjustments to help vulnerable clients during the initial or ongoing advice, six firms had stated they did not have a policy in place. And looking at those figures broken down. 957 firms include family or friends in meetings. 937 provided home visits or at least as an option. 929 used face-to-face rather than paper. 770 firms provide telephone advice. 743 had additional touch points that we've talked about already, and 620 firms used more concise or clearer documentation. And as clients get older, if they're an income drawdown, the importance of recognizing those risks increases and the FCA found that it was not clear for almost half of the firms looked at how they would be able to properly monitor vulnerable customer outcomes. They had policies in place but didn't appear to collate the data to track or measure those outcomes.

And as I mentioned earlier, and Shelley's also talked about, reviews. The FCA points out in their dear CEO letter that when it comes to examples of good practice, these are what firms should be aiming for if they're not already. And this is one that I've highlighted that you can have a look at later when it comes to reviews. And reviews are really vital to ensure that any vulnerability comes to light at the right time or as soon as possible. And these examples of good and poor practice are therefore worth looking at when it comes to reviews if you think this is something you need to adopt going forward.

So, as we said earlier, divorce is one of those life events which could mean a temporary or longer-term vulnerability and financial advisers are well placed, if not best placed to help clients through this process. Thinking about this on a purely practical level, when it comes to pensions, advisers can help the client consider any impact the divorce will have on expression of wish forms. They're in a position to help put certain public sector schemes where clients can benefit from an independent valuation to ensure the ex-spouse is receiving a fair value. With any older pension attachment orders, our advisers are definitely best placed to ensure that they still operate properly or effectively after legislative changes, particularly pension freedoms, and advisers are definitely well placed to help clients build up assets after a divorce, especially if you've lost a portion of your pension.

And when it comes to pension death benefits, it's vital to plan to ensure these are set up correctly, to make sure the benefits are paid on time and to the correct people. And this is likely when they're at their most vulnerable. So here we're not so much thinking about the member, we're thinking about the beneficiary, to which, we hope you are going to maintain that relationship going forward. So, as we said, there's been lots of changes with regards to the removal of the lifetime allowance as well as future changes to inheritance tax and pensions. So, it's vital that you keep up to date with those.

It's important to review any trust set up to receive death benefits. Are they still required? Is the client aware of the potential tax charge on death after age 75? Are they aware of the new rules?

And this one's really important. Does the plan actually offer what beneficiaries want or need? And that could be particularly important from an income tax point of view. And here we're really talking about beneficiary drawdown, because if someone dies and it's not available, beneficiary drawdown isn't available, then it's too late at that point to transfer to a provider who offers it.

Thinking about older clients with pension commencement, lump sum or tax-free cash entitlements after age 75 is important as that right to 25% tax free will die with you, as all the benefits would be subject to the marginal rate of income tax on death after age 75.

And it's vital, as we said, to make sure the expression of wish forms are kept up to date and that will make sure benefits are paid as quickly as possible and reflects your most recent wishes. And incorporate that into the review process.

Also, think about the difference between discretion and direction. If direction has been used, it's still appropriate with IHT in mind and consider changing this if necessary. That's important right now but remember it potentially won't be after April 2027 when the new roles bring pensions into the IHT arena.

So, from the 6 April 2027, any pension death benefits could be subject to inheritance tax. And this is really a massive change which could affect more people than I think we realise. Beneficiaries will definitely need your help at this time. And it could mean delays to pension benefits being paid. I'd also suggest lawyers aren't pensions experts. So, this gives you another opportunity for you to help your clients in a vulnerable situation.

And now I'm going to hand back to Shelley, who's going to take you through the remainder of the session. Thanks, Shelley.

Thanks Fiona. And as we come to the end of our webinar today, let's just finish by highlighting how providers such as Royal London can help you to support vulnerable clients.

So, literature library of client facing material. Most protection providers, us included, have a real wide range of literature on our library on the adviser website and that can support you in a whole range of formats to help your clients.

Signalling potential vulnerabilities. I think our BDMs can definitely share with you based on our pension and protection data, anything that might be a trigger for a vulnerability. It can let you see if there have been any activities that might signal a potential vulnerability, and I'm thinking here maybe missed premiums or maybe an unsustainable drawdown on a pension plan. I think clear communications are really important. We test and review our communications all the while to make sure that they are easy to understand for our clients and help them to achieve their financial objectives.

And we also offer communications in alternative formats such as braille, large print, and even audio, so you can really feel confident that we'll support your clients, including those with vulnerabilities.

Now financial wellbeing support, at Royal London, both our mobile app and also customer website give your clients access to a whole range of financial wellbeing guides and articles. Most of them are written by our in-house experts. And these cover key topics like budgeting, dealing with some of those life events that both Fiona and I have discussed, including things like bereavement and sickness, and also to understand investments.

Now emotional and practical support. Most modern protection policies these days come with a range of added value support services, and these can give clients access to a range of real handpicked early care medical services and support with both physical and mental wellbeing.

And health and wellbeing directory. Finally, we have a health and wellbeing directory that can help your clients access support services in their own geographical area. And this can include things like age-related support, help with bereavement that we've mentioned quite a few times, help with domestic abuse, or even housing support.

So, if we move on to our final slide, which will be our learning outcomes, I'm pretty confident that the objectives that Fiona set at the beginning of our webinar will have now become outcomes. So, I'll just leave those on the screen for just a second or two.

And then really all it takes as we move to our very final screen; all it takes really is from both Fiona and myself to say a huge thank you for taking the trouble to dial in and listen to us. I'll leave you with our adviser.royallondon website address that will give you all sorts of information about the things that both Fiona and I have talked about today, but as usual, for more support, we would urge you to contact your normal Royal London sales BDM. Thank you so much for listening.