Typically, affordability and customer vulnerability have sat in different parts of the business. Credit risk looks after affordability: can this person repay what they’re borrowing? Compliance and customer experience are responsible for customer vulnerability: does something about this person’s circumstances mean they need extra support? Different teams, different systems, different reports to the board.
But both are tasked with answering the same underlying question: what do we actually know about this customer? A change in employment, a bereavement, a new caring responsibility or a health diagnosis – all of these affect whether someone can sustainably meet their mortgage payments, which are all markers of customer vulnerability.
The more a firm understands about a consumer, the sharper its affordability decisions get, and the better it can identify and support those customers with characteristics of vulnerability. It’s the same data doing both jobs.
THE REGULATOR IS ALREADY TREATING THEM AS ONE PROBLEM
This isn’t a notional connection. Recent work on by the Financial Conduct Authority (FCA) on Consumer Duty steadily brings affordability and customer vulnerability closer together.
Its March 2026 review into firms’ approaches to consumer understanding found firms using reactive rather than proactive approaches to customer vulnerability. Checking for vulnerabilities was often one-off or poorly evidenced, with little ability to show that insight actually changed anything for the customer.
The same principle often applies to affordability. A calculation based on income and outgoings can tell a lender whether customer appears able to meet payments today. It cannot explain their lifestyle, health or identify other factors that could affect their ability to manage their mortgage.
Read together, these issues point to the same gap: firms that only look at a customer once, at the point of sale, using a narrow set of numbers.
A SNAPSHOT AT ORIGINATION IS NOT ENOUGH
Mortgage lending makes this particularly important, because the customer relationship can last for decades. A customer who showed good affordability at origination can become vulnerable, or unable to sustain payments, months or years later because of circumstances that have nothing to do with how the mortgage was originally underwritten.
This means affordability cannot be treated as a yes-or-no gate at application. A customer who falls outside an affordability assessment may have circumstances that warrant a different approach, while an existing customer who passes an affordability test may subsequently need additional support.
For lenders and advisers, there is a clear requirement to connect affordability and customer vulnerability earlier in the customer journey. The objective to gather better information that supports both responsible lending and good customer outcomes.
EXISTING DATA DOES NOT PROVIDE A SHORTCUT
It would be easier if a shared database of customer vulnerability already existed – a single place a lender could check whether an applicant needs extra support. It doesn’t. The closest thing, the Vulnerability Registration Service (VRS), is a genuine step forward, but its coverage remains slim relative to the actual population firms need to assess.
Some firms try to infer customer vulnerability from financial records alone – arrears patterns, income volatility or changes in financial behaviour. That can identify financial customervulnerability, but nothing about the health conditions, life events, low capability, or limited understanding that Consumer Duty also requires firms to identify and respond to.
A customer coping well financially can still be vulnerable in every other sense that the FCA cares about.
This leaves one reliable route: asking the customer directly. That can feel like a step backwards in a mortgage journey where firms have worked hard to reduce friction. The evidence doesn’t bear that fear out. Done well, a short, structured question set doesn’t impact conversion.
The extra information it gathers feeds straight back into a sharper affordability decision, not just into identifying who needs support. It’s a win-win: better outcomes for the customer and better data for the lender – all from the same short exchange.
BUILDING IT DIGITALLY, AT BOTH ENDS OF THE RELATIONSHIP
The answer isn’t more paperwork or a bigger call centre. It’s building the same structured, digital understanding of the customer at both ends of the lending relationship.
That means assessing affordability and customer vulnerability together at the point ofapplication, rather than as two separate processes. It also means continuing to track changes in circumstances through the life of the mortgage, so they’re picked up before they turn into arrears or harm.
This is what digital customer vulnerability platforms like the MorganAsh Resilience System (MARS) can do: identify, classify, monitor, support and report. The structured assessment provides an objective Resilience Rating that not only quantifies vulnerability but can be integrated into affordability criteria.
By using API connections, this becomes instant. Becausesuch systems use an objective, consistent measure, a customer’s vulnerability characteristicscan be tracked over the lifetime of the mortgage rather than recorded once and filed away.
Around half of all customers show characteristics of vulnerability, according to the FCA’s Financial Lives survey, and most of it goes undetected by front-line staff working from disclosure alone.
Knowing your customers properly isn’t a compliance cost sitting on top of good mortgage lending. It’s the same job, brought together and done well.
