UK FCA Vulnerable Customers Review

Published on: Mar 11, 2025

On Mar. 7, UK FCA issued findings on treatment of vulnerable clients.

  • FCA issued report on findings of its review of how firms are supporting customers in vulnerable circumstances and whether its existing guidance is still appropriate.
  • Published details of good practice and areas for improvement for firms to follow.
  • And encouraged vulnerable customers to open up to firms to get the right support.
  • Updated Treating vulnerable consumers fairly webpage to include details of review.
  • On same day UK FCA issued findings of Duty consumer support review, see #246344.
  • Follows UK FCA Feb. 2021 issued final guidance on vulnerable customers, see #98797.
  • Review
  • FCA gathered data to understand: actions firms have taken to understand and respond to the needs of customers in vulnerable circumstances; outcomes received by customers in vulnerable circumstances; stakeholders' view of the FCA's Guidance.
  • Included consumer research, analysis of Financial Lives survey data, survey of 725 firms, research on outcomes monitoring and on power of attorney processes in banks.
  • Findings
  • Consumer research finds that vulnerable customers more likely to report a negative experience with financial services firms when compared to non-vulnerable customers.
  • Many firms have taken positive action and made good progress in supporting customers in vulnerable circumstances, evidenced in regulator's consumer research.
  • Clear that Consumer Duty has driven a renewed focus among firms on delivering good outcomes for customers in vulnerable circumstances, but still room to improve.
  • Areas of good practice included: effective use of data to monitor outcomes, pinpoint if customers in vulnerable circumstances are experiencing worst outcomes than others.
  • Offering flexible and tailored support; firms taking steps to review and improve clarity of their messages to customers, tailor communications, provide in a timely manner.
  • Also incorporating consumers' experiences into product and service development.
  • Areas for improvement include: ineffective outcomes monitoring; failure to give appropriate support, including not encouraging customers to disclose vulnerabilities.
  • Failure to give appropriate support or accessible channels to customers in vulnerable circumstances, and a lack of testing of consumer understanding of communications.
  • Lack of tailored training and embedding consumers' needs into product and service design, accompanied by lack of training on vulnerability for product and design staff.
  • FCA gives examples, sets out prompts for firms on how to improve in this area.
  • Next Steps
  • On the basis of the review, FCA finds that the Guidance remains useful and important under Consumer Duty, so is not revising it or introducing new requirements for firms.
  • But has published case study examples of good practice and areas for improvement.
  • Regulator encourages firms to make use of these examples, and will continue to take account of outcomes for vulnerable customers across its Consumer Duty work.
  • Will also continue to engage with industry to support continuous improvement, particularly in areas that firms find more challenging re vulnerable customers.
Regulators
UK FCA
Entity Types
B/D; Bank; BS; CNSM; CU; Depo; Exch; IA; IB; Ins; Inv Co; MG Orig; MSB; Pension; Servicer; Thrift
Reference
Gd, Rp, PR, 3/7/2025; UK CNSM DTY
Functions
Complaints; Compliance; C-Suite; Financial; Legal; Operations; Registration/Licensing; Reporting; Risk; Sales Practices; Suitability; Technology; Trading; Training
Countries
United Kingdom
Category
National Regulator
State
N/A
Products
Banking; Cards; Clearing; Deposits; Derivatives; Fund Mgt; Insurance; Loan; Mortgage; Overdrafts; Payments; Pensions; Securities; Seniors; Wealth Mgt
Rule Type
Guidance
Regions
EMEA
Rule Date
Mar 7, 2025
Effective Date
Mar 7, 2025
Rule ID
246251
Linked to
Reg. Last Update
Mar 7, 2025
Report Section
UK