Called The MorganAsh Resilience System (MARS), the new tool is designed to help both advisers and firms meet the Financial Conduct Authority’s (FCA) requirements for understanding and managing consumer vulnerability. The FCA’s ‘Guidance for firms on the fair treatment of vulnerable customers’ came into force in February 2021 and will be strengthened by the ‘A new Consumer Duty’ paper, which is currently out for consultation. 

MARS is the very first system providing this type of simple-to-understand rating. While the rating system is simple it is based on highly-sophisticated data. As a result, it has been embraced immediately by St James’ Place (SJP). SJP is providing its partners with access to MARS to help them identify and better support financial vulnerability among clients.

The MorganAsh Resilience System provides an objective measurement rating like the familiar credit score used by lenders across the UK. MARS collates information from consumers and their advisers, to calculate a comprehensive ‘resilience rating’. This provides a simple, objective, and consistent way of managing consumer vulnerability. 

Resilience focused

Acutely aware of the potential stigma for an individual if labelled as vulnerable, MARS instead focuses on strengths – a person’s resilience. The highly-secure system provides simple ratings which reflect every aspect of a person’s vulnerability or resilience, including health, wealth and life events. 

The level of detail collected is tailored to both the stage of engagement and the potential for consumer detriment. For example, when a consumer is enquiring about a ‘low-risk’ product, such as life assurance, the level of detail required by MARS is minimal and may be provided by the consumer or agent. But for riskier or high-value products, such as high-risk investments, a more diligent set of information would be used with independent verification of that information.

Mortgage and financial advisers and agents can input a person’s vulnerability information themselves. Alternatively, they can ask their client to complete an online questionnaire or, if the consumer is suspected to be vulnerable, can book an assessment of their client to be undertaken by a MorganAsh nurse.

Fintech driven by the FCA’s requirements

The FCA is keen to see firms using processes to support vulnerable consumers and enable them to disclose their needs, so MARS provides a robust, rigorous framework for advisers to achieve this.

The system can be used as a standalone tool or integrated with a firm’s CRM via secure API links. MARS is already integrated with systems from Intelliflo and Iress, with more integrations planned.

MARS is independent of both providers and products and can be used by anyone in financial services, for any product or service. It is an objective measure, and provides consistent and essential evidence of regulatory rigour to compliance teams and the FCA.

Andrew Gething, Managing Director at MorganAsh, said: “Just as a credit score is used to simply communicate wealth, MARS is used to communicate health and resilience. By using MARS, advisers and firms can simply enter a consumer’s details, and the tool does the rest. This enables them to focus on what they do best – delivering the best advice.”

Robert Sinclair, Chief Executive at Association of Mortgage Intermediaries, says, “To meet vulnerability and impending consumer duty requirements, firms need to understand the characteristics of their customers – and be able to manage and report the conduct risk.  Firms’ progress to-date has largely been limited to subjective individual assessments which risk inconsistency and complexity in recording.  A move to more structured assessments that can provide consistent and objective data will provide management information that firms can utilise.  The resilience rating within the MARS tool would appear to be a positive first step.”

Johnny Timpson OBE, Financial Inclusion Commissioner, says “The FCA’s vulnerable guidance, focus on value and impending overarching consumer duty regulatory requirements will require advisers and providers to understand their customers in a far more detail – to better to anticipate and avoid foreseeable harms – plus demonstrate that they are acting in good faith to support consumers need to meet their financial objectives and experience good outcomes. We need good tech to help us do this.  The MorganAsh MARS tool – with its objective ‘resilience rating’ – is a great step to making this transition easier.”