Vulnerable customer support that asks the customer first, records the need in their own words and follows it on every channel
Support needs recorded once, with consent, and followed on every channel.
See one case, screen by screen ↓Vulnerable Customer Support is software for bank colleagues to spot customers who need extra care, record their support needs with consent and adapt service on every channel. Seven agents listen on the call, draft the need in the customer's own words, follow it through letters, fees, sales and collections, route specialist referrals and compare outcomes for customers with needs against everyone else. Colleagues ask and record, specialists check, and the Consumer Duty Manager signs.
AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →
Updated
Vulnerable customer support starts on an ordinary call. A customer rings about a payment and mentions that her husband died last month, that she wears a hearing aid, or that she is struggling. Under the FCA's FG21/1 guidance and the Consumer Duty, the bank is expected to notice, ask, record the need with her agreement and serve her accordingly on every channel. On a busy call the sign passes, and needs typed into free-text branch notes are never read by the contact center.
Then the rest of the bank carries on as if nothing had been said: an 11 pt statement to a customer who asked for large print, a credit card upgrade call to someone who asked for no sales calls, overdraft charges caused by a payment for a person who has died. The FCA's April 2025 review of retail banks found staff who did not acknowledge customers who were noticeably distressed, and recorded needs that were not consistently used. Boards see service levels, not whether customers with needs fared as well as everyone else.
Estimated split of the people's working time on one disclosure, from the call to the evidence for the board, by hand and with the solution. Our arithmetic, kept modest.
Seven agents listen, draft, follow through and compare outcomes; colleagues record with consent, specialists check.
Tuesday October 20, 2026, the Corvane Bank UK contact center in Leeds. Mrs Ann Hollis, 74, a customer since 1988, calls about a £1,250 payment that left her overdrawn. Here is what happens next, screen by screen, in the working solution.
Mrs Hollis explains that the £1,250 standing order to Westmere Lodge Care Home was her husband David's, and that he died last month. Her record already holds the needs she shared in the Harrogate branch on Mar 3, 2025: a hearing aid, large print at 16 pt and no app. The Listening agent hears a possible bereavement at 0.96 confidence and possible distress at 0.81, and prompts Ellie Marsh once, with three choices: she agreed, she declined, or ask at the end of the call.
You could say: “I’m so sorry about David. Would it help if I made a note of this on your record, so you don’t have to explain it again, and we can give you more time? You can ask us to remove it at any time.”
Ellie asks, and Mrs Hollis answers: “Yes, please do. I don't want to go through it all again.” Only then does the Needs Record agent draft a temporary bereavement need under life events, at 0.94 confidence, with a review on Apr 20, 2027, six months on. The consent passage is stored with the need. Ellie can edit the words, and an edit is logged as an override.
“Mrs Hollis’s husband, David, died on Sep 14, 2026. She would like one team to deal with his accounts, and more time on calls.”
Ellie saves the need. Calls now go to the Bereavement Support Team with extra time, nothing is addressed to Mr Hollis, there is no sales or marketing contact until Apr 20, 2027, overdraft charges are reviewed for refund until Dec 20, 2026, and no collections contact happens without a specialist. The agent proposes a £35.00 refund of overdraft charges, a Bereavement Support Team callback on Thursday Oct 22 at 10:00, and a pause of the £1,250.00 standing order due Nov 1, only if she asks.
The Follow-through agent proposes and never acts: money and account changes need a checker.
Ellie clicks “overdraft charges Oct 1–19” and reads the passage from the core banking customer record. On Oct 1 standing order SO-88213 took −£1,250.00 and left a balance of −£637.60 against an arranged overdraft limit of £1,000; on Oct 19 charges of −£35.00 took it to −£672.60. The proposal also cites the bank's Bereavement standard BS-3 §2 and the team diary.
The £35.00 refund, reason RF-02, is within Ellie's £50 mandate, so she approves it and it waits for a specialist's check. She books the callback, and a large-print confirmation letter is queued because of the need Mrs Hollis shared in her branch. On Mrs Hollis's instruction, the standing-order pause goes for a check too.
“Approved by Ellie Marsh · waiting for Priya Raman's check”
The specialist teams have 418 open referrals: 37 due today, 5 overdue and escalated, 3 checks waiting and 1 day 6 h on average to first contact. Bereavement, power of attorney, carers, financial difficulty and specialist support each have a team, a service-level chip and an owner; Mark Okonjo's mental health crisis call is urgent, due by 11:30. A suspected financial abuse referral shows only “Held by Specialist Support”.
Priya opens referral R-10418, opened Oct 20 at 11:06, first contact due Oct 22 at 17:00. She checks the £35.00 refund and posts it to core banking. The referral shows 3 of 6 steps done, the standing-order pause until Nov 30 waiting for a check, and the death certificate and the large-print statement reprint still to do.
An overdue referral goes to the team manager at the due time, then to the Consumer Duty Manager after 1 working day.
Mrs Hollis's row now shows her bereavement, recorded on a call on Oct 20 at 11:05:02 by Ellie Marsh, review Apr 20, 2027. The register holds 96,141 customers with a recorded need, 3,214 new disclosures in 30 days, 2,860 temporary needs due for review in 30 days, and 0 needs recorded without consent. Each row says how to help in plain words; health details stay with the specialists.
The Review agent asks the customer at the next natural contact. It never closes a need: a maker and a checker do.
The agent checked 412,600 contacts against recorded needs and found 61 not respected: 54 put right, 7 open, 3 h 40 min on average to put right. One is Mrs Hollis's own: her Sep 26 savings statement was printed at 11 pt. Others are a credit card upgrade call to a customer who asked for no sales calls, and an £8.00 returned payment fee on a late husband's direct debit, which waits for a specialist.
When the collections system stopped answering at 09:12, the screen said so, and queued letters were held until it was back.
For Quarter 3 the Outcomes agent compares 96,140 customers with a recorded need with all 1,412,300 customers on 9 measures. First-contact resolution is 71.2% against 78.1%, and complaints 14.2 per 1,000 against 9.6. Gap G-1: 212 bereaved customers paid £7,480 of overdraft interest in the 30 days after a bereavement was recorded. Thomas agrees the action with an owner and a date: Craig Nolan, Current Accounts Product Owner, by Dec 15, 2026.
The agents suggest stopping overdraft interest for 60 days once a bereavement is recorded, and refunding all 212; Thomas Achebe decides.
The same call, seen by the people who take it, check it, test it and answer for it: what their day looked like, and what it looks like now.
Seven agents listen, draft, follow through and compare outcomes; colleagues record with consent, specialists check.
Hears possible signs of vulnerability on calls and chats under the four drivers (a bereavement, confusion, distress, a carer speaking), quotes the passage with its confidence, checks the customer's record and prompts the colleague once, with suggested words.
Drafts the need in plain words from the conversation, with its driver, kind and review date, for the colleague to edit and save.
Applies a saved need to seven channels, looks back 30 days for what the bank owes, proposes refunds and callbacks, then checks every letter, call, fee, sales and collections contact against recorded needs.
Routes needs that need a specialist to the right team, sets the service-level clock and prepares the callback.
Finds temporary needs due for review and asks the customer at the next natural contact.
Compares nine outcome measures for customers with recorded needs against all customers and by driver, raises gaps over the 5-point tolerance with the evidence and an estimated cost of the fix, and drafts the quarterly report.
Builds evidence packs for FCA supervision, internal audit and the Consumer Duty Manager from the audit trail.
Records with consent; a specialist checks. The agents propose; a named person decides.
Colleagues, specialists and managers ask in plain words. Every answer points to its source and opens the screen it is about.
Which bereaved customers paid overdraft interest after we knew?
212 customers in Q3, £7,480 in total, in the 30 days after a bereavement was recorded. 61 of them, like Mrs Hollis, still had a payment for the person who died running. The agents suggest stopping overdraft interest for 60 days once a bereavement is recorded, and refunding all 212; Thomas Achebe decides.
Has anything we sent Mrs Hollis ignored her needs?
One thing: her annual savings statement on Sep 26 was printed at 11 pt, though she asked for large print in March 2025. The template carried no large-print setting. The fix is to reprint in 16 pt with an apology and correct the template.
Which referrals are overdue?
5 of 418 are overdue and escalated to the team manager; 37 are due today. Peter Lyons (financial difficulty, overdue 2 days, unassigned) and Hazel Brookes (bereavement, waiting for the grant of probate copy). Mark Okonjo's urgent call is due by 11:30.
How do I ask a customer about recording a need?
Use script C-4: “Would it help if I made a note of this, so you don’t have to explain it again? You can ask us to remove it at any time.” If they say no, nothing is recorded and the decline is kept with the call.
13 screens from the working solution, on its sample data. Pick one to see it large.
Consent wording, review periods, refund mandates, agents and retention are settings. Every change needs a written reason and the Consumer Duty Manager's approval; the old setting stays in force until then.
| Setting | Default | Choose from |
|---|---|---|
| Consent wording on calls | Script C-4: “Would it help if I made a note of this, so you don’t have to explain it again? You can ask us to remove it at any time.” | Your own words for calls, and for branches and the app |
| Lawful basis | Explicit consent, UK GDPR Article 9(2)(a) | Where consent cannot be given, the specialist records the legal basis |
| Review periods | Bereavement: 6 months, then ask the customer | Financial difficulty at the end of the breathing space or 3 months · temporary health 12 months · permanent every 24 months, at a natural contact |
| Refund mandates | Colleague up to £50 per customer in 90 days; a specialist checks | Specialist up to £250, a second specialist checks · above £250 the team manager approves |
| Account changes | Always maker and checker, with the customer's instruction recorded | Standing orders, attorneys and names |
| Listening agent | v3.2 · prompt threshold 0.70 · never records | A new version runs beside the old one on last month's calls before approval |
| Outcomes agent | v1.8 · gap tolerance 5 points | Never reports a group under 50 |
| Retention | Expired temporary needs deleted 90 days after the review date; consent records and the audit trail kept 6 years after the relationship ends | Call transcripts kept 12 months, with card and account numbers redacted at capture |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate, kept modest · “typical” = published figures (FCA review of firms' treatment of customers in vulnerable circumstances, March 2025: 42% of customers in vulnerable circumstances had told their firm, and 44% reported a negative experience against 33% of others; FCA multi-firm review of retail banks' treatment of customers in vulnerable circumstances, April 2025; FCA FG21/1 and the Consumer Duty, PRIN 2A). Corvane Bank UK, Westmere Lodge Care Home and the customers, people, accounts and references named on this page are fictional: characters and sample data in the working solution.
Vulnerable Customer Support is software for bank colleagues to spot customers who need extra care, record their support needs with consent and adapt service on every channel. Seven agents listen on the call, draft the need in the customer's own words, follow it through letters, fees, sales and collections, route specialist referrals and compare outcomes for customers with needs against everyone else. Colleagues ask and record, specialists check, and the Consumer Duty Manager signs.
The Listening agent hears possible signs on calls and chats under the FCA's four drivers of vulnerability: health, life events, resilience and capability. Above a 0.70 confidence threshold it prompts the colleague once, with the quoted passage, its confidence and suggested words. It never records a need and never speaks to the customer, and Compliance measures its accuracy every month.
No. Nothing is recorded until the customer agrees, and the consent passage itself is stored with the need as evidence. A decline is kept, and the prompt never repeats on that contact. Customers can see, change or remove any need.
When the colleague saves a need, the Follow-through agent applies the bank's channel adaptations to calls, letters, branch, app, sales, fees and collections. It then checks every contact against recorded needs, before a letter prints where it can and after a call or fee where it cannot, and proposes a fix for each miss. Money fixes wait for a specialist.
The Outcomes agent compares customers with recorded needs against all customers on nine measures and by driver, raises gaps above the 5-point tolerance with the evidence and an estimated cost of the fix, and drafts the quarterly report. A Compliance Monitoring Analyst verifies every number against source before the Consumer Duty Manager can sign it for the board.
Customer Support Specialists, compliance and internal audit. Colleagues see how to help, in plain words. Evidence packs redact health details by default, and call transcripts have card and account numbers redacted at capture.
Yes. The agents may not record a need, speak to the customer, move money, change an account, close a need, decide an outcome action or sign anything. A colleague approves, a specialist checks every refund and account change, and every decision carries a named person and a reason code on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your consent script, bereavement standard, review periods and channel adaptations, and it goes live once every quality gate has passed. We will walk you through it on a sample of your own calls first.
Every procedure a rule change touches is found and fixed before the rule takes effect.
1-min demoCall Compliance MonitoringEvery call and chat reviewed, not a sample, and each finding confirmed within a day.
1-min demoSecure Message TriageEvery request in a message on its own legal clock, started the day it arrives.
1-min demoWe'll run Vulnerable Customer Support on a sample of your own recorded calls and branch notes.