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Vulnerable customers – understanding and meeting the FCA’s guidelines

Updated: May 18, 2022

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:

  1. Understand customers needs

  2. Ensure staff have the right skills and capacity

  3. Implement processes for monitoring and evaluation of vulnerable consumers

  4. Review the impact of products and services delivered to consumers

  5. Put in place customer service protocols to support vulnerable consumers

  6. 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.

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