How Vulnerability Indicators Can Drive More Informed Decisions

TransUnion and the Vulnerability Registration Service have launched a partnership to help create better consumer outcomes through a new data concept

In this blog we explore what is meant by vulnerability, what non-financial vulnerability entails and the challenge faced by lenders in addressing it, before moving on to outline what TransUnion can offer in the way of financial indicators across the vulnerability spectrum and how our partnership with Vulnerability Registration Service (VRS) will provide lenders with combined indicators across the four drivers of vulnerability. Ultimately this will enable better identification, protection and outcomes for customers through empowering lenders to see a fuller data picture of consumers, and in turn making more informed and insight-led decisions.

Defining vulnerability

The Financial Conduct Authority (FCA) defines “A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.” With the continued turbulence of the macro-economic climate many UK consumers are facing difficulties with varying levels of resilience.

To highlight the scale of the challenge the FCA Financial Lives research reveals that 27.7 million UK adults now show characteristics of vulnerability.

Non-financial vulnerability and increased business accountability

For consumers facing non-financial instances of vulnerability such as life events, be it bereavement or relationship breakdown, to those with mental or physical health conditions, their experiences can be all-encompassing and life altering. Regardless of the type of vulnerability, businesses need to treat vulnerable consumers with compassion, consideration, and proactive treatment, to avoid individuals falling further into vulnerability which could lead to financial difficulty.

The FCA’s Consumer Duty guidance clearly outlines that firms need to take more accountability for the part they play in treating vulnerable customers fairly, preventing them from harm and offering them greater financial inclusion, choice and empowerment. The underlying message is vulnerability is not a tick-box exercise and taking this approach will not suffice.

The challenge of non-financial data

Currently non-financial vulnerability indicators are not as readily available or integratable as their financial vulnerability counterparts. Some indicators can be considered to be sensitive information e.g. addiction, health and disabilities, and these are not readily asked for when collecting data. Fear of discrimination can lead to consumers not wanting to disclose this information. This provides businesses with a major challenge in terms of collecting information and being able to use it in their big data sets, even before they start considering how best to use the data in decisioning or treatment strategies.

Navigating the way towards a combined view of non-financial and financial vulnerability indicators

How TransUnion supports businesses with financial stress and vulnerability indicators now

TransUnion’s financial indicators, indices and datasets are wide ranging and can support businesses across the customer lifecycle, throughout acquisition with Affordability Report, customer management using TrueVision trended data, and early care arrears stages to identify, indicate and in some instances predict financial vulnerabilities consumers are experiencing, as well as those displaying signs of financial stress.

Identifying consumers showing signs of financial vulnerability

There are several indicators that businesses can use to identify signs of financial vulnerability including: income shock, low-income indicators, high debt to income ratios, high debt levels, disposable income stress, and budget deficit indicators. In response to recent macroeconomic pressures, TransUnion has developed new indicators including mortgage payment shock and water and fuel poverty – valuable additions especially as the impact of the cost of living crisis continues to be felt. These indicators help businesses get a clear picture of what is happening to their consumers and where action may need to be taken.

Detecting financial stress

To detect financial stress TransUnion offers indicators that show: use of high-cost credit, regular use of overdrafts, persistent debt such as credit cards, being overlimit on credit, using revolving credit, debt trajectory and derogatory data such as CCJs on file with associated collection searches. These indicators offer businesses a wider data picture of the consumer’s financial experience, empowering them to take swift action to support consumers and avoid them falling foul of greater financial harm.

Determining signs of financial difficulty

TransUnion can also determine signs of financial difficulty through indicators displaying missed payments on mainstream credit, utilities arrears, defaults, late payments and arrears, forbearance on credit, debt management plans, County Court Judgments (CCJs) and insolvencies.

Data innovation and partnership: bridging the gap to provide businesses visibility across the four drivers of vulnerability

TransUnion has strong financial stress indicators in the resilience and life event categories of the FCA’s four drivers of vulnerabilities, however, our ability to support businesses and vulnerable consumers in the health and capability categories was sparse. TransUnion’s purpose is to use Information for Good, through economic inclusion, great experiences and personal empowerment for consumers and businesses. With vulnerability such an important topic, we worked to find a partner to help us find alternative data sources to bridge the gap.

Watch: Learn how TransUnion and the Vulnerability Registration are working together

Partnering with the Vulnerability Registration Service

We’ve partnered with VRS, a UK not-for-profit organisation dedicated to supporting vulnerable consumers. VRS offers consumers a single platform to register their vulnerable status, sparing them from repetitive and challenging conversations with various lenders and organisations.

This partnership allows access to a comprehensive, independent register of vulnerable individuals, empowering TransUnion to identify vulnerabilities (categorised into cognitive ability, debt, life event, financial, fraud and physical attributes), merge them with financial indicators, and provide them to businesses, empowering organisations to make informed decisions in alignment with regulatory guidance.

What this partnership means for consumers and businesses

The partnership will enable TransUnion to produce a comprehensive set of vulnerability indicators which cover all four FCA vulnerability drivers, enabling businesses to gain deeper and broader data insights that they can use to more effectively identify, predict and protect vulnerable consumers at risk of harm.

Adding to this Helen Lord, CEO of VRS shares “the partnership between VRS and TransUnion is a massive move towards a central route for consumers to share their vulnerability. And it's addressing a problem that every single sector has, every regulator is facing. It is a massive step towards our ambition of having that single vulnerability route that will support consumers.”

Kelli Fielding – Director of Solutions at TransUnion UK – says “our collaboration with VRS marks a significant leap in understanding consumer vulnerabilities. Our data shows that financial and non-financial vulnerabilities are linked and by merging these datasets, we empower lenders to offer tailored support."

Sam Newman – TransUnion’s vulnerability expert - goes on to explain further: “Through TransUnion incorporating VRS non-financial indicators into our own existing vulnerability indicators we’ll create a simple-to-use, powerful data set, that businesses can take through us directly, and use effectively in their decisioning and operations.”

In summary

Vulnerability is wide-ranging and can be difficult to detect in large data sets – especially non-financial vulnerability, which is less readily accessible. The FCA Consumer Duty guidance calls on firms to take more accountability in treating vulnerable customers fairly, preventing them from harm and offering them greater financial inclusion, choice, and empowerment. TransUnion can support lenders now with financial indicators and indices across the vulnerability spectrum.

Through the unique partnership between VRS and TransUnion, we’ll soon be able to combine non-financial and financial vulnerability indicators together, empowering businesses with robust coverage across all four drivers of vulnerability. This enhanced view of vulnerability will give greater representation of consumer vulnerabilities and help businesses create informed treatment strategies and demonstrate that they’re actively looking to identify vulnerable consumers, and keep them from harm, as part of their regulatory obligations.

Read more about vulnerability in our latest ebook: Managing Vulnerability: Leveraging New Data to Improve Customer Outcomes.

If you’re a consumer with questions or issues related to your personal credit report, drivers history report, disputes, fraud, identity theft, credit report freeze or credit monitoring services, please visit our Customer Enquiries page for assistance.

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