Section D·Consumer DutyConsultation draft v0.1
Vulnerability
The file must show that the adviser looked for signs of vulnerability, and what they changed if they found any.
5 required itemsRequired evidence
A recorded check against the four FG21/1 drivers: health, life events, resilience and capability
Where a driver was present: what adjustment was made (more time, a third party present, simpler explanations, a cooling-off period)
Evidence the client understood the key risks, in their own words or by a recorded check-back question
Consent recorded for holding any health or personal information
Where financial difficulty is a driver: free debt advice signposted before any recommendation
A file that records "no vulnerability identified" with no sign of a check does not meet the standard. Consolidation cases often involve low financial resilience, so the check carries more weight there.
The Specialist Lending File Standard is not legal or compliance advice and does not replace FCA rules. Information for professional intermediaries, not advice. Comment on the draft.