MARS helps firms meet Consumer Duty and Vulnerability regulations (4:44)

A secure, easy-to-use system, which significantly aids compliance with the FCA’s Consumer Duty and Vulnerability regulations.

For those in financial services, understanding consumers’ characteristics is both an opportunity and a challenge. It’s an opportunity that’s seized and challenge met with the MorganAsh Resilience System – MARS.

We want vulnerable consumers to experience outcomes as good as those for other consumers and receive consistently fair treatment across the firms and sectors we regulate. We expect firms to provide their customers with a level of care that is appropriate given the characteristics of the customers themselves.

– The FCA’s ‘Guidance for firms on the fair treatment of vulnerable customers’

A comprehensive Consumer Duty and Vulnerability management system

There is an increasing need for financial services firms to understand their consumers – and to record any actions taken to ensure good, fair outcomes. The MorganAsh Resilience System – MARS – is an easy-to-use, online system which enables organisations to accurately assess consumers’ characteristics and any potential harms – and then recommend appropriate actions to mitigate those potential harms in a consistent, structured way. It helps firms meet, and demonstrate compliance with, the FCA’s Consumer Duty and Vulnerability requirements. 

MARS generates an objective, consistent ‘Resilience Rating’ – like a credit score. MARS also helps to determine next steps needed to mitigate any potential harm. This is all supported by on-demand human services (provided by a team of fully qualified nurses) to help with more difficult assessments – and to provide additional services which support vulnerable consumers. 

MARS rating

MARS assesses a range of vulnerability characteristics including health, wealth, lifestyle and support network to derive an objective assessment of consumer resilience.



  • Holistic assessment criteria, covering relevant characteristics, including: health, wealth, lifestyle and support network.
  • Assesses consumer characteristics by direct input, online questionnaire (emailed to the client), look up of the VRS (Vulnerability Registration Service) or an independent assessment by MorganAsh nurses.
  • Calculates an objective measure of resilience/vulnerability – ‘the MARS Resilience Rating’ – enabling detailed reporting to meet Consumer Duty’s evidence requirements for management – including support for fair value and target market analysis.
  • The ability to monitor changes in circumstances and characteristics over time – MARS is a ‘lifetime’ system.
  • Highly flexible and configurable – can be adapted to meet the precise needs of any organisation. This includes assessment criteria, detailed questionnaires, ‘next step triggers’ and more.
  • APIs (application programming interfaces) enable integration with standard and bespoke CRM systems, and the real-time transfer of consumer information, to avoid double-handling of data.
  • Underpinned by a team of fully qualified nurses, to provide expert human help and assistance whenever needed.


  • Demonstrable compliance with the FCA’s Consumer Duty and Vulnerability regulations.
  • Saves users’ time, without adding compliance overhead.
  • Improves understanding of consumers, enhancing engagement.
  • Lifetime data, to monitor changes in vulnerability over time and across transactions.
  • Enables cross-department and cross-company communications, by managing the complexities of vulnerabilities – and presenting them as a simple to communicate Resilience Rating – just like a credit score.

Vulnerability isn’t binary

Vulnerability isn’t a yes or a no. Many people can be classified as vulnerable – and for many, the vulnerability is invisible. Many current means of assessing vulnerability are simply too superficial and, most importantly, don’t bear regulatory scrutiny. That’s why MARS has a sophisticated rating system and algorithms which take a comprehensive range of factors into account. Yet, when MARS has done its work, it provides the easy-to-understand ‘Resilience Rating’ – like a credit score. It’s simple, fast and objective. Plus, it encompasses a comprehensive range of potential vulnerabilities.

Free trial

You can try a complete, unrestricted version of MARS for a full month, free of charge. Simply request access our trial system to get started.

Consumer Duty expertise

MorganAsh is a leading specialist in Consumer Duty and customer vulnerability solutions for the financial services sector. Tap into our expertise via our blogs, webinars and podcasts.


MARS has a feature-rich API, enabling it to be easily integrated with other systems.

  • Intelliflo
  • Iress

Find out more


We have two pricing tiers, delivering different levels of functionality. Our pricing model is simple: for regulated firms, we charge per adviser; logins for administrators and paraplanners are free. For product providers, lenders and banks, fees are per assessment/search, based on volume.


  • Online and adviser assessments
  • Calculated resilience rating
  • Vulnerability report per assessment
  • Management reports
  • Logos on consumer communications
  • Customisable treatments
  • Configurable messages in consumer communications
  • Up to 20 assessments per month


  • Choice of online, adviser or nurse assessments
  • Calculated resilience rating
  • Vulnerability report per assessment
  • Management reports
  • Integrations via API to other systems
  • Logos on consumer communications
  • Configurable messages in consumer communications
  • Customisable treatments
  • Each consumer checked on VRS - Vulnerability Registration Service
  • Up to 40 assessments per month

Sign up for free access

You can try a complete, unrestricted version of MARS for a full month, free of charge. Simply request access to our trial system to get started. We’ll be in touch and help set up the system in the way that works best for you. After one month, we will automatically begin invoicing you. If you have questions, just get in touch with us – we’ll be happy to help resolve any queries.

  • Full access to all features
  • No limit on number of advisers
  • No limit on number of paraplanners
  • We’ll help get you started

Sign up for a free trial

We’re here to help

If you need help to get started or to resolve any queries, please let us know. We’ll be happy to help.

We’re here to help 

If you need help to get started or to resolve any queries, please let us know. We’ll be happy to help. We want to make adopting MARS as easy and effective as possible. This can encompass onboarding just the MARS system, or helping your organisation to understand and implement greater organisational support for interacting with vulnerable consumers.

Fitting in with current processes

Although MARS is designed to be quick and easy to implement, it may need customising to fit in with your process and systems. Talk to us – and we will guide you through configuration options, system integration capabilities and how others are using the system.

Support to get you going

Adopting any new system, adding new business processes, or changing the way in which you interact with customers and vulnerable people can take time and require help. We want you to make a success of using MARS and help you meet the FCA’s Consumer Duty and Vulnerability regulations. Every organisation is at a different stage on this journey, so we can work with you – by understanding where you are now, and helping you adopt MARS as part of a Consumer Duty strategy.  


MARS has a full-featured API and is designed to integrate with other systems, such as CRM applications. Priority of integration is determined by demand. If you need MARS to integrate with other systems, then please contact us so we can help you.

Treatments – what to do next and when to provide additional support

Many organisations are concerned that an increased understanding of vulnerabilities will lead to extra costs in supporting consumers. We think this is unlikely. We work with organisations to understand when it is appropriate to add additional services and when it is not. This is always in line with organisations’ conduct risk policies, compliance with the Equalities Act – and financial and customer service criteria.  

For help using MARS, or integrating MARS with your current systems, please contact us. We’ll be happy to help.

InstallationHow do I install MARS?

MARS is software as a service, accessed via any standards-compliant Web browser. No installation is required. This allows you to access MARS from almost any device and almost any location. An internet connection is required.

Help with the trialWhat if I need help to find my way around?

MARS is designed to be simple and straightforward to use, so we encourage you to dive in and use it. If you’d like a guided tour, or some help, please contact us.

SecurityHow secure is MARS?

MorganAsh is an ISO 27001-certified company, certificate 215374 – this is an international standard for managing information security. MorganAsh is a Cyber Essentials Plus-certified company, certificate IASME-CEP-003810 – this is the highest level of certification offered under the Cyber Essentials scheme. All client/consumer data is kept secure on our bespoke systems.

RegulationHow is MorganAsh regulated?

The collection of consumer characteristics, assessment of potential harms and ongoing monitoring is, under Consumer Duty, a regulated activity. To comply with this MorganAsh is authorised and regulated by the Financial Conduct Authority (No 451227). The specific permissions covered are: (for both insurance and investments): arranging (bringing about) deals in investments; assisting in the administration and performance of a contract of insurance; making arrangements, with a view to undertaking transactions in investments. Full details can be found on the FCA register.

ComplianceWhat about data protection?

MARS is fully compliant with GDPR. MorganAsh is responsible for the storage and deletion of all data in accordance with GDPR, and for recording consumer consent where electronic questionnaires are used. Firms and their users are responsible for obtaining the requirement for the data and obtaining consent and for the storage and deletion of any downloaded reports.

CustomisationWhat happens if MARS doesn’t quite meet our needs?

For those organisations whose needs are not met by MARS, our system is designed to be extensible and customisable. Feel free to contact us about your specific needs.

IntegrationCan MARS talk to our other systems?

Our API enables integration with other systems. Current integrations include Intelliflo and Iress. We are extending this in line with demand. Other integrations are available on request.

Why MorganAsh?What are MorganAsh’s credentials?

MorganAsh has enviable experience assessing consumers’ health and lifestyle characteristics, via clinical and cognitive assessments, since 2004 – exclusively for the financial services sector. We have assessed the health of thousands of consumers and looked after hundreds of severely ill consumers. We combine bespoke systems with empathy-driven clinical expertise, to deliver award-winning services. Since our formation in 2004, we have had few Financial Ombudsman Service complaints and zero found against us. There has never been an event reported to the Information Commissioner’s Office. Our customer complaints record is exemplary with only four complaints in the last three years.





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Manor Park
United Kingdom

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