In this guide:

Overview

The Key now offers a more detailed option for recording the status of potentially vulnerable clients that will identify both the category and sub-category of the vulnerability, details and a summary of action taken.

This option can be enabled via Setup. If the option is not enabled, the current functionality will remain in place.

NOTE: This is a ‘one-way’ change to the behaviour of The Key. Once the enhanced functionality has been enabled, it is NOT possible to return to the previous, simplified, version.

The detailed vulnerability data is enabled through Setup > General > Reports/Fact Find > Fact Find Configuration and selecting ‘Custom Fact Find Settings’. Within this screen select the checkbox ‘Use detailed Potentially Vulnerable Client data capture?’.

Figure 1: Enabling Enhanced Vulnerability

Once selected, The Key will warn the user that this is an irreversible change. Click on ‘OK’ to apply the change or ‘Cancel’ to return to the previous screen.

NOTE: The enhanced functionality will apply to all sales created on the day the change is implemented and thereafter.

Figure 2: Vulnerability Confirmation

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The potential vulnerable customer question remains located in Fact Find > Client Cont. The new functionality will be triggered if a ‘Yes’ answer is recorded.

Figure 3: Recording a Vulnerability

This will trigger a new pop-up window called ‘Client Vulnerability Data’ which is where all vulnerability data will be managed for this client.

Figure 4: Client Vulnerability Data

When recording the first vulnerability, the user will be taken directly to the screen above for recording the vulnerability details.

Once the vulnerability category has been selected, the appropriate sub-category can then be chosen.

Details of the vulnerability can be added, along with the actions taken in light of the vulnerability (if any).

Figure 5: Example of Completed Vulnerability

If, at any point, the user wishes to abandon the process, clicking on ‘Cancel’ will return the user to the Client Cont. screen. Alternatively, once the vulnerability details have been recorded, clicking ‘OK’ will add this vulnerability to a table listing all vulnerabilities recorded to this client.

Figure 6: Manage Client Vulnerability Data

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This list is taken from section 2.9 of FG21/1: Guidance for firms on the fair treatment of vulnerable customers.

If a vulnerability has already been recorded, clicking the ‘More’ button associated with the potentially vulnerable question will open the ‘Manage Client Vulnerability Data’ screen. From this screen, a new vulnerability can be added through the ‘Add’ button and completing the information as per the first vulnerability.

Figure 7: Recording Subsequent Vulnerabilities

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The ‘Manage Client Vulnerability Data’ screen will also allow the user to edit any previously recorded vulnerability data, or to delete any items that are no longer needed. If all items are deleted, then the question in Client Cont. will be set to ‘No’.

The new functionality is supported by a number of new merge fields as detailed below.

<<CLIENT2.POTENTIALVULNERABLECUSTOMER_VULNERABILITIES_1>>

<<CLIENT2.POTENTIALVULNERABLECUSTOMER_VULNERABILITIES_2>>

The above fields will list all of the enhanced vulnerability detail (for applicant 1 or 2) in a single field.

Alternatively, individual vulnerability details can be shown by selecting the individual merge fields listed under the heading of (for example) Vulnerability1_App1 (where the number 1 refers to each vulnerability/applicant respectively.

For example, <<VULNERABILITY2_APP2.CATEGORY>> will display the category of the second vulnerability recorded against applicant 2.

Overview

This functionality (when enabled) will require the recording of a client fee when a mortgage or loan product is noted as moving to application. The client fee can be £0.

This behavior is mandated by restricting the user’s ability to record ‘post-application’ information unless the client fee is recorded.

The functionality is enabled on the Setup > General > General screen, by selecting the option ‘Mandate Client Fee for Mortgage or Loan Products’.

Figure 8: Enabling Mandatory Client Fee Functionality

When selected, the user will be asked to confirm when the new functionality is to take place from (this will default to today’s date). This can be amended for a future date if required.

Figure 9: Date Selection

The functionality will apply to mortgage and loan products created after the option is enabled.

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The following changes are made to the pre-application screens for mortgage and loan products.

The application tab is now initially displayed in a read-only status, except for the AIP/DIP Completed data item. The data fields will only become available after the product has been applied for. The new ‘Product Applied For’ button shown on this screen is used to initiate the client fee check as outlined below.

Figure 10: Initial State of Application Tab

The available Status options will also be restricted to those related to a pre-application state.

Figure 11: Mortgage Status Options (Pre-Application)

It will not be possible to manually add a work list if the mortgage or loan is in a pre-application state. This prevents automated work list functionality from bypassing the client fee check.

Figure 12: Disabled Work List Pre-application

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When a product moves the application, the first step is to click on the ‘Product Applied For’ button.

Figure 13: Product Applied for Button

This will automatically take the user to the Product Details > Commission tab where they will be prompted to check the fees recorded against the product, in particular the status of the client fee.

Figure 14: Confirm Fees Prompt

If a client fee is present, the user will be able to select the ‘Fees Correct’ option. This will enable all the other post-application options (application tab, status options and work list creation) that were previously disabled. There is no need to save and re-open the product.

If no client fee is present, the ‘Fees Correct’ option will be disabled (as above). The user will then select ‘Edit Fees’ to access the Product Details > Commission screen to add the client fee. It will not be possible to move on unless a client fee has been recorded – if the user tries to move on the prompt will reappear.

Figure 15: Client Fee Added

Once the client fee has been added, the previously disabled functionality will automatically be enabled. The user will not be required to save and reopen the product, or to confirm an additional prompt. The ‘Product Applied For’ button will also show the green tick as another confirmation that the step has been completed.

Figure 16: Application Tab Updated

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Two changes have been made around password management to apply enhanced security to the application.

The minimum password length for The Key will be increased to 12 characters. This will apply to any new accounts, or where the password is updated or reset.

Figure 17: Password Rules

It is now no longer possible to disable the ‘brute force’ protection by setting a value of 0 as the number of failed login attempts before disabling an account. This minimum value is now 5 (and this will be the default value for any new installations).

A new report has been created to support the enhanced vulnerability data that can now be

recorded. This report is located in Reports > Compliance and called ‘PVC Report (Enhanced Detail Report)’.

A new report has been added to Reports > Commissions called ‘Commission Details for advisers (paid). This lists commissions that have been paid to advisors, including details of the gross amount and all splits.

The report is designed to replace the ‘Commission Statement for all advisers between commissions paid start date and end date’ which is no longer supported.

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