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Detection & Support for Vulnerable Customers

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Ensure your dealership meets FCA expectations with our integrated Detection & Support feature, built into the TCF software. Designed to help identify vulnerable customers early in the sales process, this essential tool promotes fair and ethical treatment of all customers whilst also upholding and supporting consistent and compliant decision making.

What Qualifies as Financial Vulnerability?

The FCA recognises several drivers of vulnerability. These include:

  • Financial hardship
  • Physical or mental health conditions
  • Recent bereavement
  • Cognitive impairments
  • Low literacy or numeracy skills
  • Limited digital access or capability
  • Life changes such as divorce or redundancy
Man signing car insurance document or lease paper. Writing signature on contract or agreement. Buying or selling new or used vehicle. Car keys on table. Warranty or guarantee. Customer or salesman.

Risks of Non-Compliance

Failure to detect and support vulnerable customers can lead to:

FCA enforcement actions and fines

Poor customer outcomes

Reputational
damage

Increased risk of complaints or legal challenges

How Our Detection & Support Feature Works

Our TCF software integrates Comentis' Duty of Care Assessment tool directly into your sales process enabling real-time evaluation and support of potentially vulnerable customers.

  • Automated Vulnerability Assessments

    Using advanced criteria and behavioural indicators, the system evaluates the customer's responses from the Duty of Care Assessment for signs of vulnerability automatically.

    For example, the assessment may include questions such as:

    • Is English your first language?
    • Do you have a hearing or visual impairment?
    • Are you currently experiencing a challenge to your physical and/or mental health?
  • Real-Time Alerts for Sales Executives

    If a potential vulnerability is flagged, the system notifies the sales executive immediately, prompting a tailored and compliant approach—for example, slowing down the sales process, providing additional explanation or offering alternative communication methods. This helps safeguard both the customer and your business.

  • Reporting & Documentation for Audits

    All vulnerability assessments and outcomes are recorded, providing a clear audit trail—reinforcing the dealership’s ability to meet FCA requirements and uphold the Consumer Duty principle already outlined in the compliance section.

Detection & Support
Step-by-Step Flowchart

Integrated with TCF Software

Vulnerability Assessment

Potential Vulnerability Detected

Tailored Support Measures

Benefits of Detection & Support

Early warning system for vulnerable customers

Integrates seamlessly with TCF Software and is triggered at the first step in the sales process

Enables reliable, FCA-aligned decisions throughout the customer journey

Ongoing Sales Support

To ensure your team uphold Treating Customers Fairly (TCF) and FCA Consumer Duty principles and remain FCA compliant and confident in supporting vulnerable customers, we offer tailored training courses designed specifically for you.

They ensure staff:

  • Understand how customer’s make decisions and how to identify decision making problems.
  • Understand what constitutes vulnerability (temporary or permanent conditions affecting decision-making or communication)
  • Can identify the signs of vulnerability during interactions—whether face-to-face, by phone, or online
  • Know how to adapt their approach to protect vulnerable individuals and avoid mis-selling or poor outcomes
  • Are confident in taking appropriate steps—such as slowing the process, offering support, or involving others when necessary

Each course is tailored to reflect real-world dealership scenarios, helping your staff act responsibly, ethically, and in full alignment with FCA expectations.

As with all our training courses, sales team members who let them expire or have not yet completed them will be unable to move forward in the sales process—maintaining complete system integrity and peace of mind for you.

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STREAMLINE & ENHANCE PERFORMANCE WITH

A flexible platform that works the way you need

Built on a flexible and fully supported platform, specifically designed to be beautifully simple and easy to use while maintaining compliance in a multitude of areas.

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