Fair treatment of vulnerable customers has been a longstanding concern for the FCA .
The FCA has released the Finalised Guidance (FG21/1).
It sets out its view of what firms should do to comply with their obligations under the Principles and ensure they treat vulnerable customers fairly.
To briefly summarise, there are six key actions you will need to take to ensure you are treating customer fairly:
Understand customers needs
Ensure staff have the right skills and capacity
Implement processes for monitoring and evaluation of vulnerable consumers
Review the impact of products and services delivered to consumers
Put in place customer service protocols to support vulnerable consumers
Consider whether your communication is comprehensible for vulnerable consumers
Customer vulnerability should be considered across every part of the business, and the regulator will propose enforcement in this area.
You will also need to consider areas covering
Governance and responsibilities of senior management
Culture, capacity and competency
Product Management
Communications
Monitoring and oversight
We will soon release a paper providing you with a comprehensive overview of the guidance. It highlights key questions you should consider and proactive steps you can take to meet the guidelines.