Last Friday, the FCA announced that it would conduct a review of the actions that firms are taking to understand and respond to the needs of customers in vulnerable circumstances. The review will determine whether firms are supporting vulnerable customers fairly and delivering outcomes for them which are as good as for other customers, by looking at:
- firms’ understanding of customer needs;
- the skills and capability of staff;
- product and service design; and
- communications and customer service.
Also, as part of this review, the FCA will conduct consumer research and gather information from firms and consumer representatives. They will share their findings by the end of 2024.
Vulnerability is a keystone of Consumer Duty and the treatment of vulnerable customers has been high on the FCA’s list of priorities for a number of years (this link provides very helpful guidance on dealing with customer vulnerabilities). When Consumer Duty was launched, the FCA said it would apply a “vulnerability lens” to its supervisory and enforcement activity and it certainly appears that it is delivering on its word.
Please do get in contact if you would like to discuss your approach to dealing with vulnerable customers, or have any queries about what you are expected to do.
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