This is a key priority for them and they provided some research from a recent study that showed 50% of UK adults displayed one or more characteristics of being potentially vulnerable. This is a remarkably high number and likely to increase further in the coming years.

This consultation is in no way criticising the sector, as they acknowledge that most firms want to do the right thing by clients. But what it does show is the need for consistency across financial services.

When thinking about vulnerable clients, it is easy to just think that it applies to the older generations and those approaching or in retirement, but vulnerability can strike at any age. It can occur after a major life event such as a bereavement, divorce or bankruptcy among other things.

For those in the front line of the SIPP industry, it can be emotionally draining and difficult to manage these vulnerable clients, and in particular on the administrators that have often been dealing with them for many years, be they young or old.

We had a delightful SIPP client who had been with us for many years, he managed his own investment portfolio through a stockbroker. But last year, his wife contacted us to say that he had been diagnosed with dementia. Fortunately for the family, he had signed a Lasting Power of Attorney many years ago, which the family had now decided to invoke. After completing all the relevant paperwork, our systems were amended.

You would think this might be an end to this situation, but in fact it was the start. Due to his confusion, he would call in and ask his administrator to purchase shares, sounding very lucid on the phone. We would then receive calls from his wife to check that we hadn’t transacted anything, which of course we wouldn’t. It was a difficult time for the wife and our administrator who would try to explain the situation to him, but he would forget that he no longer had control over his finances.

With changing demographics, more stressful lives and increased longevity the issue of vulnerability will only increase. As an industry we all need to work together to create best practice. The FCA are keen to hear more about what firms are already doing in terms of activities, policies and processes – so they can create revised draft guidance. They are also looking at several other projects and initiatives that are relevant to vulnerable consumers.

This can only be a good thing as many of us will be in this situation in the years to come.

Elaine Turtle is a Director at DP Pensions