Enhancing support for vulnerable customers in the financial sector

Apr 9th '24

Vulnerable Customers Introduction: A New Era Of Regulatory Focus.


The financial services industry is at a pivotal juncture, with regulatory bodies intensifying their scrutiny on the treatment of customers in vulnerable circumstances. The Financial Conduct Authority (FCA) has been at the forefront of this shift, signalling a clear mandate for firms to elevate their understanding and support for these customers. This article delves into the critical aspects of the FCA’s recent communications, outlining the imperative for firms to adapt and refine their strategies to meet evolving regulatory expectations and customer needs.


Understanding vulnerability: a broadened scope


Evolution of the regulatory perspective

In March 2024, the FCA announced a comprehensive review targeting the practices financial service firms employ to identify and support customers facing vulnerability. This review, anticipated since 2017, extends beyond initial projections focused on age-related vulnerabilities to encompass a wider array of circumstances that might affect customers’ financial wellbeing.


 Key factors for assessment

The review’s scope is extensive, evaluating firms’ approaches from multiple angles:


  • Initial and Ongoing Understanding of Consumer Needs: How firms establish and update their understanding of customers’ circumstances.
  • Staff Skills and Capabilities: The training and expertise provided to employees to recognize and address vulnerability.
  • Product and Service Design: The inclusivity and accessibility of offerings to cater to diverse customer needs.
  • Communications and Customer Service: Whether firms’ interaction strategies effectively support fair treatment for all customers, especially those in vulnerable positions.


Importance of a multi-faceted approach

The recent “Dear CEO” letter and joint communications with regulatory counterparts highlight the critical nature of addressing debt and vulnerability comprehensively. The spotlight on these issues underscores the need for a holistic approach, integrating sensitivity to vulnerability across all facets of business operations.


Strategic imperatives for financial firms

Firms are now tasked with not only reevaluating their policies and processes but also embedding a culture of empathy, inclusivity, and responsiveness. This section provides actionable insights for firms aiming to align with the FCA’s heightened expectations:


  • Enhanced Training Programs: Develop comprehensive training to equip staff with the knowledge and tools to identify and support vulnerable customers effectively.
  • Customer-Centric Product Design: Innovate product and service offerings to ensure they are accessible and beneficial to customers with varying needs and circumstances.
  • Proactive Communication Strategies: Implement communication channels and messages designed to reassure, inform, and support customers, facilitating a sense of security and understanding.
  • Ongoing Policy Evolution: Establish mechanisms for continuous learning and adaptation of policies to reflect emerging insights into customer vulnerability.


Conclusion: a call to action

The FCA’s intensified focus on vulnerability demands a strategic and compassionate response from the financial services industry. By embracing the regulatory imperatives and integrating them into their core operations, firms can not only meet but exceed regulatory expectations, fostering an environment of trust and support that benefits both customers and the industry at large.


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LS Consultancy is a Affiliate Member of the Consumer Duty Alliance, which is an independent, ‘not-for-profit’ professional body. It aims to support the personal finance sector in the adoption and implementation of the FCA’s Consumer Duty requirements through the alliance of like-minded individuals and firms.


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