"This recent scrutiny from the FCA should send a clear message that firms will need to get on the front foot if they haven't already."
- Jonathan Barrett, CEO of Comentis
The FCA has announced that it is conducting a review into how firms are acting to understand and respond to the needs of customers in vulnerable circumstances.
Under Consumer Duty, firms should act to deliver good outcomes for all customers, including those with characteristics of vulnerability.
The review will look at firms’ understanding of consumer needs, the skills and capability of staff, product and service design, communications and customer service, and whether these support the fair treatment of customers in vulnerable circumstances.
The FCA will also look at the outcomes consumers in vulnerable circumstances receive and whether they’re as good as the outcomes of other consumers.
Rather than conduct a separate piece of work focussed solely on age related issues, as first announced in 2017, the review will look more broadly at how firms treat customers, including older customers, in vulnerable circumstances.
Jonathan Barrett, CEO of Comentis, commented: “The recent FCA review regarding how firms treat their customers in vulnerable circumstances is undoubtedly the clearest message we have seen so far that the FCA is taking customer vulnerability seriously.
"This recent scrutiny from the FCA should send a clear message that firms will need to get on the front foot if they haven't already. Consumer Duty sets the expectation that vulnerable customers must be identified, and that their outcomes should be no less favourable than non-vulnerable customers.
"The best way to ensure this is by a systematic process for screening clients and appropriate accommodations for the needs of those at risk. By combining clinical expertise with hard data, these kinds of solutions can remove bias and subjectivity from the process, ensure consistency across a whole client base and reassure firms that their systems will adequately meet the scrutiny of regulatory requirements.”
