Context
The FCA has updated its Consumer Duty web page adding a section in relation to Vulnerability. The FCA wants firms to be able to identify customers in vulnerable circumstances, understand their needs, and act to meet those needs where necessary.
Key points to note and next actions
Under the Consumer Duty the FCA expect firms to actively encourage customers to share information about their needs or circumstances, where relevant. Firms should try to recognise the needs of consumers, whatever channel they use.
Firms should:
- set up systems and processes that enable customers to disclose their needs; and
- support staff to actively identify signs of vulnerability, for instance through training and resources.
Firms that speak to customers face to face or on the phone can support staff to:
- recognise observable signs of vulnerability; and
- encourage the customer to discuss their needs.
Firms failing to capture such information are highly unlikely to meet the needs of all their customers.