An estimated 15% of the UK population are neurodiverse
It is thought that 15% of the UK population are neurodiverse, with around 8% in the UK having ADHD and around 10% having dyslexia.
David Robinson (pictured), regulatory director at Konexo, said the waves of requests for change to communications from neurodiverse people have taken a long time to reach mortgage providers and finance professionals. However, mortgage contracts will require adjustments for neurodiverse customers moving forward under Consumer Duty.
Communications tools
Robinson believes that a range of communications tools need to be prepared and made available ahead of the looming Consumer Duty deadline.
“Neurodivergence is a broad term covering a range of conditions and capabilities; support can be achieved in a number of ways, such as using diagrams to explain concepts, and the use of concise and precise sentences,” he said.
Other support for the neurodivergent, Robinson added, can include using closed questions over open ones, as well as avoiding humour than can often be taken too literally.
It is a varied and highly nuanced area, but Robinson said it is essential to navigate if you are to ensure customer understanding.
“The consequences of not doing so may be non-compliance with Consumer Duty, and the risk of the Financial Conduct Authority (FCA) taking action,” he said.
Worse than this, Robinson added, is the reputational damage of non-compliance and potential adverse publicity. He believes there is also a good chance that as competitors offer these services to the neurodiverse, this group of customers will vote with their feet and choose other providers to obtain a mortgage if their specific needs are not being met.
“Given that Consumer Duty will also mean more information is freely available to customers, there is more work involved to ensure that the full range of requirements for the neurodiverse are considered for a variety of information,” Robinson said.
Commission, interest rates, pricing, fees, term, cancellation rates, consumer survey feedback and complaints data, Robinson said, could all be freely available and therefore may need to be translated.
“Despite the difficulties and scale of work needed to prepare for when Consumer Duty comes into force, it will be much simpler and cost-effective to have a response ready than to make this a distress-driven reactive task,” he said.
Gathering momentum
Before now, Holly Short, principal associate at Eversheds Sutherland, said there have been few requests to consider and implement reasonable adjustments for neurodiverse people.
“We believe that awareness of neurodiversity and increased knowledge of individual rights have caused the first ripples in the water,” she said.
Add to this the well-publicised dawn of Consumer Duty on July 31, and Short said these ripples of requests for change are forming into waves and gathering pace.
“Firms and their advisers have finally had sufficient time to gather a full understanding of the detail and the impact of the requirements of Consumer Duty,” she said.
The key part of Consumer Duty, and the requirement that will drive more requests for neurodiverse adjustments, Short said, is that it demands firms deliver good outcomes for customers and place customers’ interests at the heart of their activities. Short added that firms also need to demonstrate that the outcomes that would reasonably be expected are being achieved and, where they identify that good outcomes are not being achieved, act to address this.
“Firms will have to challenge themselves to ensure that actions are delivering good outcomes for customers,” she said.
Positives of Consumer Duty
The FCA outlines there is an opportunity to increase ‘public confidence in the regulatory process and show that misconduct will be uncovered and dealt with’.
Short said this will give the mortgage industry a better connection with its customers.
“Those doing this correctly will be able to receive priceless feedback from potentially hundreds of thousands of people a year, that may have previously struggled to be part of an evolving broking and lending system,” she said.
There are many firms already preparing their changes, but Short said there will also be those who are not.
“Being able to have communication with and from the neurodiverse is a vital part of Consumer Duty compliance, but it will also be a vital part of becoming a stronger broker and lender in the years and decades to come as the whole industry looks to change for the better,” Short said.
What impact do you expect Consumer Duty to have on neurodiverse communications considerations? Let us know in the comment section below.
