Vulnerable Customer Statement
At Heartland we are proud to have helped over nineteen thousand Australians live a more comfortable retirement with our reverse mortgage. We aim to provide customers with peace of mind and have a culture that places significant importance on the duty of care we have for every customer.
One of the ways we do this is to ensure our staff are aware of potential vulnerability in our customers, and that they take steps to provide the appropriate support to ensure we are lending responsibly.
Answers to frequently asked questions
Vulnerabilities may be permanent, temporary (short or longer term) or sporadic. They can occur at any time.
Heartland is committed to responsible lending. We will always ensure the loan, and its purpose, is of benefit, and is suitable for the customer – this includes debt repayment, gifting, and asset purchases.
Our reverse mortgage protections video can be viewed here, and provides an outline of these protections.
Barriers that prevent a person from interacting ‘as normal’ with Heartland or prevent them from acquiring information.
Problems with understanding, remembering and assessing information.
Circumstances which may predispose an individual to a poorer outcome, or there is an inference of vulnerability
If a customer’s age may predispose them to a potentially poorer outcome, we may take extra steps to ensure we are comfortable with competency.
This includes hearing, sight, or limited mobility.
This includes brain injury, mental health, living with dementia, or financial illiteracy.
This includes English as a second language, recent immigrant, isolated, recent bereavement, and financing the expenses of family members.
Addictions such as gambling, alcohol, drugs, shopping – whether by the customer directly or through a family member.
Recent divorce, high level of debt, little income, large number of dependents.
Any situation which is identified as vulnerable will be treated with an appropriate level of care to ensure that the customer is not being taken advantage of.
Heartland will follow our Elder Abuse Guidelines if a red flag for abuse is identified.
We will also assess loan use, and ask further questions to ensure our lending is responsible, examples of how we act are as follows:
If a loan purpose is for gifting, our Gifting Guide will be followed.
If the loan is to repay a debt, or there are high levels of debt, suitability and benefit will be assessed.
If the purpose of loan is for investment or business purposes, independent financial advice will be required.
Scam or Fraud
If, on assessment of an application, it appears that loan funds are being used to pay a scammer, or fraud is being committed, we will not lend until we have comfort funds are being used for the direct benefit of the borrower.
If the loan purpose appears likely to be used for an addiction, such as gambling, Heartland will not lend until we have comfort funds are being used for the direct benefit of the borrower and not to protract or support addictions.
Communication channels include phone, email, webchat, and in person at our Melbourne office. If there is a language barrier during the application process, we will review our network of mortgage brokers to identify and offer appropriate assistance.
The solicitor should be able to communicate to the customer in their chosen language.
- The customer is unable to sign for themselves;
- The funds are for the benefit of the Nominated Borrower(s); and
- The order has not been revoked.
Heartland also requires a certified copy of the documentation (or confirmation it has been lodged with the appropriate Land Title Office).
Post settlement, we will vet any new Power of Attorney requests, including a legal review and onboarding of any Customer Agent.
If we do not receive the annual questionnaire, Heartland will take additional steps to ensure that our customers are safe and contactable.
- Fear that telling someone about their vulnerability will lead to losing a family relationship, possible retaliation, or further loss of independence;
- Be reluctant to believe that someone they trust is exploiting them;
- Want to protect any perpetrators, if they are being taken advantage of, from legal repercussions;
- Fear they will not be believed, or that their situation will be taken seriously with an appropriate response;
- May not realise their vulnerability if information is being withheld from them, or account statements and other mail have been redirected.
At all times, privacy procedures are followed. If a child or friend of a customer calls, no information will be released unless there is permission provided (an authority letter, Power of Attorney, Administration or Guardianship in place.).
2. Customer Discussion
Frontline staff should listen to the customer. If there are concerns raised directly by the customer, they should always be taken seriously and documented on the lending system.
Criticism or negative responses to customer situations are to be avoided. A supportive and understanding approach which aligns with Heartland’s duty of care is crucial in a red flag investigation.
If there are red flags, and third parties have included themselves into the financial transaction without due cause, the customer should be contacted without the third-party present for an independent conversation.
All concerns and suspicions are escalated to management immediately if financial abuse is suspected or confirmed. Heartland may:
- Not offer a loan;
- Not provide additional funds;
- Delay the release of funds until investigations can be made;
- Report fraud to the Police;
- Notify protective agencies (such as the Public Advocate) if there has been an abuse of Power of Attorney, or Administration/Guardianship order;
- Speak to any additional account holder(s), attorneys, or signatories;
- Request permission to speak to other family members to assist;
- As part of the application, require a medical certificate to confirm capacity of the borrower;
- If there is an immediate fear of safety, contact the Police; and/or
- If the customer cannot be contacted directly, request a Police welfare visit.
It is important that questions are asked to determine the customer’s true situation. Depending on this situation, and the customer’s requirements and objectives, they may or may not be vulnerable.