vulnerable customer testing
Vulnerable Customer Testing for Mortgage Brokers
FCA rules require mortgage brokers to evidence that vulnerable customers can genuinely understand and act on pre-application disclosures. Behavioural research with neurodivergent participants gives you that evidence, captured from real interactions, not assumptions.
Your Vulnerable Customer Obligations Are Not Met by Policy Documents Alone
The FCA's Consumer Duty, introduced under PS22/9, requires firms to demonstrate good outcomes for all customers, including those with characteristics of vulnerability. For mortgage brokers, that obligation runs through every step of the customer journey: from initial affordability conversations and KFI disclosures through to the point of application. A written policy stating that your process is accessible is not the same as evidence that it works.
Neurodivergent customers, including people with ADHD, dyslexia, and anxiety-related conditions, interact with mortgage broker portals and disclosure documents in ways that differ substantially from neurotypical users. They may miss critical affordability warnings, abandon multi-step application forms at the wrong point, or misread rate comparison tables. These are not edge cases. They are patterns that only become visible when you observe real behaviour.
Regulators are increasingly asking firms to show their working. Behavioural evidence, documented from real sessions with real users, is the kind of audit trail that supports a credible vulnerable customer framework. Without it, your compliance position rests on assertion rather than observation.
Pre-application disclosure must enable the customer to make an informed choice, including their ability to afford the mortgage in the event of likely future changes
For mortgage brokers, the MCOB requirement around pre-application disclosure is not a background obligation. It sits at the centre of the customer journey, at precisely the moment when a neurodivergent customer is most likely to encounter a usability barrier. Affordability warnings, rate change scenarios, and repayment illustrations are dense, conditional, and often presented in formats that create genuine comprehension difficulty for people with dyslexia, ADHD, or anxiety-related processing differences. Behavioural research captures whether a customer actually understood that information, not whether it was technically present on the page. That distinction is what makes observed session data relevant to your MCOB compliance position, not just your accessibility programme.
Our approach
Recruit from a neurodivergent panel matched to your customer profile
OpenScouter recruits participants with ADHD, autism, dyslexia, and other cognitive differences who reflect the demographic range of mortgage applicants. Sessions are remote and moderated, covering the specific journey steps that matter for your firm: affordability tool interactions, KFI review, and the application form itself.
Capture three behavioural streams simultaneously
Every session records interaction signals including clicks, scrolls, and rage clicks, alongside think-aloud voice and locally processed facial expression data. The three streams are correlated by an AI pipeline to surface moments where a participant's stated understanding diverges from their actual behaviour, which is precisely the kind of gap that creates vulnerable customer risk.
Deliver human-confirmed reports your compliance team can use
AI correlation produces candidate findings. A human researcher reviews and confirms each one before it reaches you. Reports are structured around specific journey steps and map directly to the FCA's outcome-based framework under Consumer Duty. They are evidence, not legal opinion, but they are the kind of structured evidence that supports a robust vulnerable customer review.
What you receive
- Participant recruitment from a neurodivergent panel, with session notes on each participant's relevant characteristics
- Session recordings with timestamped behavioural annotations across all three data streams
- AI-correlated findings reviewed and confirmed by a human researcher before delivery
- A written report structured around your mortgage application journey steps, from affordability disclosure through to submission
- A prioritised list of usability issues with recommended remediation actions, suitable for sharing with your compliance and design teams
Frequently asked
- How is this different from a standard accessibility audit?
- An accessibility audit checks whether your platform meets a technical standard such as WCAG 2.2. Behavioural research with neurodivergent participants shows you what actually happens when a real person tries to complete your mortgage application journey. The two are complementary. OpenScouter is specialised in the behavioural side.
- Which FCA rules are most relevant for mortgage brokers commissioning this kind of research?
- Consumer Duty under PS22/9 sets the overarching outcome-based standard. The FCA's Mortgages and Home Finance Conduct of Business Sourcebook, known as MCOB, governs pre-application disclosure obligations specifically. Both frameworks require firms to consider whether customers with characteristics of vulnerability can genuinely understand and act on the information they are given.
- Will this research satisfy the FCA if we are reviewed?
- OpenScouter reports are structured evidence, not legal opinion. They document observed behaviour from real sessions and map findings to specific journey steps. Whether that evidence satisfies a particular regulatory review depends on your wider compliance framework. What we can say is that documented behavioural evidence is materially stronger than undocumented assertion.
- How long does a typical engagement take?
- From study brief to delivered report, most engagements complete within two to three weeks. Participant recruitment, session scheduling, and report production all happen within that window. If you have a specific compliance deadline, we can discuss whether the timeline is workable before you commit.
- Do you test the full mortgage application journey or specific parts of it?
- We scope each engagement with you before recruitment begins. Some clients want end-to-end coverage from the affordability calculator through to the final application submission. Others focus on a specific disclosure document or a single form stage where they have already identified drop-off. Both approaches are valid and the scope shapes the participant brief and session design.
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Talk to a behavioural researcher
Tell us about the vertical, the journey, and the evidence you need. We will scope a pilot in days, not weeks.