PIMFA
Customer Vulnerability Conference Highlights
- What is customer vulnerability?
A vulnerable customer is “someone susceptible to harm due to their personal circumstances, especially if a financial services firm is not acting with appropriate care.”¹ All customers are at risk of becoming vulnerable, but the risk is increased by particular characteristics, which could include poor health, certain life events, low resilience to cope with financial or emotional shocks, or low literacy or numerical capability.
The 2021 FCA guidance, ‘Guidance for firms on the fair treatment of Vulnerable Customers’, sets out expectations for firms, and the Consumer Duty has further emphasised the importance of vulnerability and has created further guidance and opportunities for firms to support customers.
- Key FCA expectations for firms:
- Consider the diverse needs of your customers at every stage of the customer
journey and across the product and service lifecycle. - Have effective systems and processes in place.
- Have effective staff training in place.
- Be proactive. Don’t just wait for customers to tell you about vulnerability.
- Take action. Identification of customers with characteristics of vulnerability isn’t an end in itself.
- Monitor the outcomes experienced by customers in vulnerable circumstances and continually improve
This guide provides support for firms to identify, support and achieve good outcomes for vulnerable customers.
latest news
April 2025
Financial Conduct Authority – retail banking multi firm review on the treatment of customers in vulnerable circumstances (findings)
The Financial Conduct Authority (FCA) has published good and poor practice to help firms provide the right support to consumers affected by bereavement or registering a power of attorney, in alignment with Consumer Duty.
Whilst there are specific findings pertinent to banks and building societies, the FCA note that this multi-firm review fed into the wider work on how financial services firms are treating vulnerable consumers and that no firm can afford to be complacent in this area.
The findings cover four themes: policies and procedures, identifying and responding to customer needs, outcomes testing and monitoring and, customer journeys.
