Consumer duty and vulnerability – protecting your customers and your business

The FCA focus on vulnerable customers is not going away. And it’s no longer just for those who deal with customers at the sharp end.

The Finalised Guidance published in 2021 presents a far wider approach, with an expectation that all areas of the business which impact customers should give due consideration to potential vulnerabilities. The inclusion of areas such as product development and IT means the impact could be widespread, particularly given the current focus on using client portals to access accounts rather than sending paper documents.

Close on the heels of the vulnerable customers’ requirements, the FCA announced their Consumer Duty proposal, which brought an enhanced expectation of care and consideration across the whole customer cohort.

The combination of these two initiatives has the potential to significantly impact the business model of some firms and call into question established (and profitable) business practices.

In our webinar, we examined the detail of these two proposals, and discussed how you should respond to them by taking a customer-centric but proportionate approach which balances the regulatory and revenue expectations. We looked at how to apply changes ‘with the grain’ of the organisation to meet the requirements in line with operational realities.