MorganAsh and Key have been working together over the last year to enable later life advisers to identify and measure vulnerability, in line with the requirements of Consumer Duty. 

Using MARS and its objective ‘Resilience Rating’, Key has completed pilots with consumers to obtain personal information and build a comprehensive picture of vulnerability. The results show positive levels of engagement with no consumer complaints and important information on consumer resilience secured.

Importantly, Key has highlighted that approximately 50 percent of its customers are potentially more vulnerable which is comparable to the findings of the FCA Financial Lives survey.  While this is not definitive – it is a good benchmark as the Financial Lives survey is an extensive piece of research.  

Will Hale, CEO of Key, the UK’s largest equity release advice firm said: “Good customer outcomes have always been at the heart of how Key transacts business so we are constantly looking at how we can better achieve this.  In the current climate and with later life lending continuing to grow in popularity, it’s absolutely vital we fully understand the vulnerabilities of our customers so that we can build our service to best meet their needs. The work with MorganAsh and the MARS platform has proven very successful in helping us to reach this goal.  

“With the Consumer Duty legislation due for introduction in July, we are also looking at ways we can improve our assessments and ensure we can provide consistent reporting to our senior team.  Good customer outcomes will continue to be our focus but what this means will evolve and gathering this type of data will provide us with another opportunity to monitor changing customer characteristics over the lifetime of the product.” 

The MARS system and its rating methodology enables lenders and advice firms to provide solutions based on a personalised understanding of individual client circumstances. Rather than each adviser undertaking a subjective assessment, MARS provides a consistent outcome. This removes the need for extensive training on how to handle and record vulnerable characteristics or what is appropriate to record to comply with GDPR. 

The MARS tool also includes its own decision engine, allowing each company to configure relevant next steps – referred to as “treatments” – for each consumer characteristic in each circumstance. In the next step, MorganAsh and Key will continue to configure treatments to best assess characteristics and apply vulnerability policy consistently across the company. 

Andrew Gething, managing director at MorganAsh, said: “MARS was carefully designed to provide an impartial and consistent outcome every time on a client’s vulnerability and resilience. Nowhere is this more important than in markets such as the later life lending arena which are specifically designed to cater to older customers who may be more vulnerable.

“MARS is already proving its worth for Key, successfully identifying vulnerable characteristics in a consistent manner.  Not only is this great for consumers, but it takes a considerable burden off individual advisers and provides the necessary data needed for Consumer Duty.

“Training staff on every option of how to cater for consumer characteristics would have been a mammoth task and can become a massive overhead. Instead of this overhead, the MARS tool enables company policy to be communicated to all users instantly and to be available when particular circumstances occur. It’s a great use of technology to clearly improve customer outcomes.”

To find out more or access a free trial, visit: or email 

For more information, please contact: Ashley Robertson, bClear Communications 
07453 278753 (m) or 01275 542511 (d) or via email:

About MorganAsh

MorganAsh provides highly differentiated support services for the financial services sector, which combined bespoke technology solutions with human empathy – within a regulated environment. Its services include absence intervention, medical underwriting, tele-interviewing and online data-gathering and vulnerability management. MorganAsh works with the majority of UK and Ireland life insurance companies.

MorganAsh has built the MARS tool to enable advisers and providers to better understand their customers and to be able to communicate this in a consistent, fair and GDPR-compliant manner and be able to monitor this over time. MorganAsh provides guidance and assistance in implementing vulnerability projects across organisations, as well as configuring the MARS system where necessary.

Vulnerability management - MorganAsh

About Key

  • Part of Key Group, Key is the UK’s largest independent equity release adviser – committed to high levels of customer service and the belief that good advice is key to ensuring people make smart sustainable choices around how they use their housing equity.
  • Key splits its advice proposition into separate brands – Key Later Life Finance, offering fixed fee (£599) advice on more than 80 equity release products and The Equity Release Experts, which provides a whole of market service. This is designed to offer customers real choice as to the service that’s right for them without compromising on quality.
  • With over 70 industry and consumer awards under their belt, the Key team offer advice on equity release, later life mortgages and retirement interest-only products. The company also provides support with estate planning including wills and lasting power of attorneys.
  • Key is committed to putting customers at the heart of what it does and has a score of 4.7 / 5.0 from over 16,640 scores on the independent review site, Trustpilot. 
  • Key is committed to being independent, transparent, and straightforward.

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Our clients say:

The FCA’s drive towards looking after vulnerable customers sets to change the way we manage our customers. To many, this looks like a daunting task. The MorganAsh MARS tool should make its implementation far easier.

Steve Devine, Protect Association