RegSol Blog

Brokers and Treatment of Vulnerable Consumers: Practical Considerations

September 2019

Vulnerable Adults often find themselves excluded from mainstream society. Excluded from the community because they are restricted in capacity and cannot read social cues, excluded from social media because they cannot navigate technology, marginalised by society because of their age, illiteracy, disability, physical or mental ill health, they are on the fringes because they do not fit in.

Despite their perceived marginalised status, vulnerable adults are becoming more mainstream and businesses and organisations alike are taking notice:


The OECD Adult Skills Survey shows that 17.9% or about 1 in 6, Irish adults are at or below level 1 on a five-level literacy scale. Ireland ranks 15th out of 24 participating countries. At this level a person may be unable to understand basic written information.

25% or 1 in 4 Irish adults score at or below level 1 for numeracy compared to just over 20% on average across participating countries. This places Ireland even further down the international rankings in 19th place.

42% of Irish adults score at or below level 1 on using technology to solve problems and accomplish tasks (Nala Ireland)

Age: 65 years and over

This age group saw the largest increase in population since 2011, rising by 102,174 to 637,567, a rise of 19.1%.  The census recorded 456 centenarians, an increase of 17.2% on 2011.  

Over half a million or 577,171 in this older age group lived in private households, an increase of 19.6%, while those in nursing homes increased by 1,960 to 22,762. (CSO)


By 2041 the numbers of people in Ireland with dementia will have tripled. In fact, a conservative estimate suggests that by 2041 some 140,000 people will have dementia. (Dementia Ireland)

Mental Health

It is estimated that one in four people will experience some mental health problems in their lifetime. The WHO’s Commission on Social Determinants of Health stated that depressive mental illnesses will be the leading cause of disease in high income countries by 2030. (Mental Health Ireland)

Serious Illness

Every 3 minutes in Ireland someone gets a cancer diagnosis. Incidence of cancer is growing and by 2020, 1 in 2 of us will get a cancer diagnosis in our lifetime.*

  • By 2020, 1 in 2 people in Ireland will develop cancer during their lifetime.*
  • In Ireland more than 40,000 new cases of cancer or related tumours are diagnosed each year. (National Cancer Registry of Ireland (NCRI))

How should brokers treat vulnerable consumers when providing them with financial advice? What accommodation should be made with a consumer presenting with these conditions and how should a Broker proceed to ensure they are acting fairly, professionally and in the best interests of these types of consumers especially if they are subject to financial abuse?

The table below provides some guidance on how to employ resources effectively in acting in the best interests of vulnerable consumers:

If you would like more information on how to effectively implement your consumer protection code requirements or would like to receive Consumer Protection Code training, please contact your consultant/trainer at RegSol.

*1 in 2 by 2020 is a projection based on current data provided by the NCRI. It makes allowances for variables such as aging population, lifestyle and other factors.

By: Judy DeCastro - Regulatory Consultant