Financial vulnerability and Monzo

This conversation started in the two new fees topic:

We're adding two new fees, which only affect a minority of customers.

Let’s continue the chat about financial vulnerability here.

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Interesting idea though the FCA estimate that approximately 50% of adults are vulnerable at any particular time according to their definition and this was pre-Covid which will have caused the number to increase.

I’m not sure Monzo would be resourced for this and I suspect relying on customers to self declare might also not be taken kindly by regulators.

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I understand your concerns around this and, of course, the exact way they implement it will be up to Monzo.

I was really just thinking about how Monzo might be able to reduce the feeling of being “on the spot” with a customer service agent on chat, and a form (as it’s depersonalised) may help in this area.

Another possibility is for their processes to still go through a form, as I suggested, but to have to initiate a chat first to get the link to it. In this way, the chat would act as an initial filter on the customer’s eligibility and only if it was thought appropriate would the form be offered.

I recognise the difficulty, of course, around this: make it too easy to self-certify, and the process would be open to abuse; make it too difficult and some genuinely vulnerable customers would be put off or missed. This is why I think it would be fair for the specialist team to make a final adjudication based on a list of internal criteria.

I also think a more form-based approach could save on resources for Monzo as it would mean that chats wouldn’t be long winded and full of detail; the detail would be put into the form in the customer’s time.

I wonder what others might think?

I think this was around something like “at risk of financial vulnerability” rather than meaning that they actually were vulnerable? This is just from memory, but I do doubt that it would be 50% of Monzo’s customers.

What is their definition of it?

You can read about it here:

The section of note:

Our Financial Lives survey 2017 found that 50% of UK adults display one or more indicators of being vulnerable: physical and mental health; life events; financial capability and financial resilience. That means half of all UK consumers may be at increased risk of harm – from making poor decisions or being at greater risk of mis-selling or being excluded from products or services.

That just says a lot without saying much.

It’s not very clear about their definitions or anything. It just seems like them trying to say something for the sake of saying it.

Perhaps it’s just my understanding of it, but the section I quoted clearly outlines the indicators they use to define whether or not someone may be financially vulnerable.

  • physical health issues
  • mental health issues
  • Life events (death, marriage, childbirth, relocation)
  • Your capability to manage your finances
  • Your financial resilience

Are all of the indicators they appear to be using to define whether or not the customer may be financially vulnerable.

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But that’s exactly it, someone above was saying Monzo shouldn’t have to ask people, but how can they possibly know?

Those criteria are so vague. You could suffer from them all and you’re fine and don’t need Monzo to categorise you as anything or suffer from one and it be too much for you.

With access to their financial data, I think in a lot cases it can be possible to make assumptions about your customers, so you can pre-empt and foresee, and help protect them.

There are spending patterns they may pick up, which could also indicate some of those. There are other predictive factors that can be used to also help determine the likelihood of you becoming vulnerable.

I think an easy example here would be redundancy. Your income would stop, the bank would be able to tell.

Another would be relocation, your bank could see transactions that indicate buying a house, or moving home.

They have visibility over your financial ability, and are in a good position to assess to your financial resilience and how well you’re managing your money. Are you budgeting pay check to pay check? Spending more than is coming in? Sending large sums of money to a creditor? Payments bouncing? Signs they’re in arrears?

A sudden or large increase in gambling transactions could intricate the customer is mentally vulnerable.

These are just some examples, and based on what @Dan5 said in the chat thread about how most people except their vulnerable customers no longer see chat. So they’re already doing some transparent behind the scenes stuff to assess that. It’s not a foolproof thing by any means, and people will slip through the net, but it can and is being done by banks already.

I still have the chat button, likely because they’re aware I’m diagnosed with Asperger’s and find it difficult to communicate verbally, though I don’t consider myself financially vulnerable.

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But what’s what I mean, all of that is obvious to a bank that has all the data.

My mental health isn’t, the death of a family member, stress at work, looming redundancy.

Re your Aspergers, is that something you openly declared during sign up/another point? As to help you with future comms?

I openly declared it, only quite recently in order to request the ability to use one of the more accessible verification options for verifying my identity if I ever need to go through it in the future. So I can hold up a piece of paper instead instead of speaking the phrase and getting all flustered.

I presume that’s why they left chat enabled for me too, as, judging from the FCA criteria, it’s an indication that I may be financially vulnerable.

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The FCA are currently consulting on their updated guidance on vulnerable customers

It includes quite a few things to do on appropriate communication channels and having more then one way to contact a firm for instance - as customers may find one method difficult.

Not all vulnerable customers see the chat option

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Yes that’s what I said it’s not foolproof and some will slip through the net. I think one or two people mentioned this in the chat thread. Something that Monzo could and should improve upon I feel.

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This example is one which seems obvious on the face of it but might not be. You may have just changed the account your income is paid into to another, or you may be paid irregularly as normal. For example, one scenario I can think of is work for small local authorities like parish councils. They pay everybody who has done work for them after the expense has been approved at the next meeting - so you might get paid at odd-seeming and difficult to predict intervals. I imagine many self-employed people would be similar, particularly if their legal setup is to have a limited company. They might time payments to themselves from the company differently depending on their needs, as they might want to keep large amounts of the money “in the company”. Income also could be erratic but “normal” for people on zero-hours contracts.

It just goes to show that this sort of thing is extremely difficult. It does generally come back to discussion with a customer, usually, and training staff to be looking out for warning signs that a customer may have particular needs. It helps if the customer is open and self-declares at the beginning, but it’s totally understandable that not all customers will want to do that (or even realise they can do that).

There are some good points being made in the thread so far, thanks to all who have contributed.

I also agree with @Peter_G that it makes sense to discuss this aspect of Monzo’s support in a dedicated thread.

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Oh hey! You just found a flaw in my logic, and explained why in a tactful way!

You make great points that I’m very much in agreement with you on.

I’m not sure we’ll ever be fully adept to the ins and outs of what banks are doing being the scenes to both identify and help those customers who are most at risk of financial vulnerability.

The thing (I hope) we all agree on, is that improvements could and should be made to these systems, so the no one is left excluded, but also so that people aren’t incorrectly marked as financially vulnerable either, as that would take resources away from those who may need it the most.

Although I respect it may never be possible, it would be nice to have a bit of deeper transparency into how this stuff works behind the scenes. There have been a few blog posts over the years that promised follow ups, which never really happened. Would be nice to perhaps to get some updates on those regarding any progress and improvements that have been made.

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This is a good point from the FCA and one I feel that many financial institutions, not just Monzo, should look at compliance for.

All traditional banks require a branch visit for certain more-complicated activities, and this discriminates against people who have difficulty accessing transport. Monzo uses chat and, I believe, this is the only way to sort out some things - the phone service is not completely full service, if I’m correct.

So it would be good for banks to consider the needs of customers in their contact options a bit more completely. Traditional banks really ought to look at allowing further interaction digitally to promote inclusiveness, and fintechs need to consider the needs of those who may have difficulties using technology.

The question may come up of “why would you use Monzo if you find technology difficult” but this doesn’t excuse the need to cater to these customers if they have opened an account and given the service a try.

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Absolutely, I couldn’t agree with you more!

I think Monzo’s efforts in this area have been positive, so I hope they do update us in a bit more detail too.

Thanks for the polite comments, I have appreciated your contributions too!

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Here’s an interesting related blog post they made over a year ago, committing to accessibility.

We’ve never had an update on this, despite stating this:

We want to assess where our product is in terms of meeting accessibility standards. This year, we want to carry out an audit of our product. We’ll share our findings once this is completed!

Then we have this post, which is excellent:


I think the process here is actually similar to something someone suggested as it’s akin to filling in a text box that goes straight to the correct team rather than having to go through chat. Hopefully this becomes more prominent as the transition to self serve deepens, because I personally missed this and went through chat.

Then over a year ago we got an update on this functionality:

Again, excellent stuff, and some great insight into how it’s helping people and works behind the scenes.

Monzo deserves some applaud and respect for the work they’ve done here, not just for putting this system into place, but for openly discussing it in such a transparent way and spreading awareness.

But, there’s been a lot of silence on this front since then, which I think really needs rectifying. It would be nice to have another update, sharing some insight, future improvements, spark an open discussion. And this all ties back into the first post I linked to on accessibility. The commitments made to accessibility will ultimately go along way to making help more accessible for those who need it too.

Edit:
I forgot to include these help articles relating to this too: https://monzo.com/help/your-needs

These are also well written, and if you access them in app, they start the flow that leads you to the text box to tell Monzo about your needs.

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Yes, I feel the same.

I suggested the text box, but the way I was thinking about it was more of a quiz-type flow of questions (not sure what they might ask, but basically tailored towards identifying if you need support so I imagine the Monzo team would think carefully about what to ask and how to phrase it) with a section at the end along the lines of “anything else you want to tell us which may be affecting your finances”, or something to that effect.

This way, the quiz flow would help make it easy but if you felt vulnerable and there was nowhere obvious in the flow that identified that you would be given the opportunity to explain your specific circumstances at the end.

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