Contacting your existing clients
Which past clients to contact first, what the data protection and marketing rules allow, how to write the message under Consumer Duty and what to record.
Which past clients to contact first, what the data protection and marketing rules allow, how to write the message under Consumer Duty and what to record.
Every past mortgage client holds facts on file that were current when the case completed. Some of those facts point to a planning need today. Start with groups where the file shows one.
You are contacting these clients anyway, so the planning question rides on a conversation already planned.
The repayment plan on file may no longer hold.
Clients whose mortgage ends after their planned retirement age, with the retirement income on file now several years old.
Clients over sixty with a home of significant value, for whom the estate and later-life lending are live questions.
Clients with several buy-to-let mortgages.
Clients whose deposit came from family, where the giver's own planning may be unresolved.
Clients whose income and wealth sit in a business.
Pick one group to start. Limit each round of contact to the number of clients you can follow through.
Before you contact anyone, check two things with whoever handles data protection for your firm.
The first is your privacy notice. It has to tell clients that you may contact them about their wider finances and, with their agreement, pass their details to a regulated financial planning firm. If the notice the client received at the time did not say that, a contact about their mortgage is still in order. Raising the introduction then becomes a question you ask during that contact, with consent taken there and then.
The second is electronic marketing. An email or text that promotes a third party's advice service is marketing, and the rules on unsolicited electronic marketing apply. The exemption for marketing your own similar services to existing customers may not cover an introduction to another firm. Where the client has not opted in to marketing, contact them about their mortgage and raise the planning question in that conversation. Calls and letters have their own rules, so check your firm's position on each.
Remove from your list any client who has opted out of contact, any client you know to be bereaved recently, and any client in arrears or in discussion with a lender about payment difficulty. Those clients need a different conversation.
Consumer Duty requires communications that a client can understand and act on, and it rules out pressure. Test the message against those points before it goes.
Wording you can use“Your mortgage with us runs until 2041, past the retirement age you gave us when we arranged it. If you would like to talk through how your retirement income and the mortgage fit together, I work with Equity & General, a firm of regulated financial planners, and can ask one of their planners to call you. Reply to this message if you would like that. Your mortgage is unaffected whatever you decide.”
Have someone outside the team read it before it goes. If they cannot say in one sentence what the message is asking, rewrite it.
Clients in later life, clients who have been ill and clients who have recently been through a separation or bereavement may need more time and a different channel. A phone call from an adviser they know suits some. A letter they can show to a family member suits others.
If your file shows a client has asked for a family member or attorney to be involved, contact them in the way the client asked. If you are unsure whether a client can make the decision, do not take consent for an introduction. Speak to your compliance lead first.
Reply within two working days to anyone who responds. A client who replies yes gets the same introduction process as a client in a live case: separate consent, a short record and a handover through the partner portal.
A client who asks a question about pensions or investments in their reply gets a short answer that the planner is the right person for it, and the offer of the introduction. Do not answer the question yourself, even briefly.
A client who replies about their mortgage gets a mortgage conversation.
The facts that put a client on your list were true when the case completed. Some will have changed. A client recorded as employed may now run a business. A couple may have separated. A client who gave a retirement age of sixty-seven may have already retired.
Write the message so it does not depend on the fact still being true. Refer to what the client told you at the time, and invite them to correct it. When a client replies, update the file before anything else happens, and use the updated facts in any introduction.
Check contact details before you send. A message sent to an old email address shared with a former partner can disclose a client's finances to the wrong person. Where the file shows a separation since completion, contact the client by phone first.
Some clients will reply that the timing is wrong. Ask when would suit them and put the date in your diary. Contact them once on that date, with the same offer. If they say not yet a second time, record it and leave the subject until their next mortgage review.
Do not move a client who said not yet into a more frequent mailing. Under Consumer Duty, a client who has given you an answer has told you something about what they need, and repeated contact on the same subject works against that.
Run the contact with past clients as a monthly task. Each month, run the list of product transfers due, interest-only maturities and terms running past retirement, and contact the clients who appear on it for the first time.
Keep the record for each client on their file. Your network or compliance team can then check a sample against your privacy notice and the marketing rules in an afternoon.
Count three things each quarter: the clients contacted, the clients who replied, and the clients introduced who went on to meet a planner. The first number tells you the task is running. The third tells you the introductions are reaching the right people.
Keep complaints and opt-outs in the same report. A rise in either means the message or the selection needs changing.
Running a lifetime mortgage or retirement interest-only case so the estate, pensions and family are considered before the lending is agreed.
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How the income evidence on a self-employed or director case points to planning needs, and when to introduce the client.
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Recognising vulnerability on a mortgage case, deciding when to make an introduction, and handling consent, family and attorneys.
Read itYour firm keeps the mortgage and protection advice. Equity & General gives the pension, investment and estate planning advice, and a named partnership manager sets the arrangement up with you.