The findings are now out! The FCA have published new pages following their review in relation to customers in vulnerable circumstances:
“Firms’ treatment of customers in vulnerable circumstances – review” (link)
And
“Delivering good outcomes for customers in vulnerable circumstances – good practice and areas for improvement” (link)
Scope
- Interviewed stakeholders from consumer organisations, trade associations.
- Commissioned quantitative and qualitative consumer research, including a survey of 1500 consumers
- Explored a broad range of poor outcomes using established measures within the 2020, 2022 and 2024 Financial Lives survey data
- Analysed responses from 725 firms to a voluntary multiple-choice survey
- Sent a follow-up information request to 29 firms across 12 markets
Findings
- Firms to continue working on defining good outcomes
- Greater focus and attention on metric setting, measurement and reporting
- No commitments from the FCA – onus on firms to keep improving
Positives to Take Away
- No new guidance or rules are proposed
- Many firms had taken positive action and supporting customers in vulnerable circumstances
- Consumer Duty has resulted in renewed focus amongst firms on delivering good outcomes for customers in vulnerable circumstances
- 75% of vulnerable customers who told their firm about their circumstances reported that they were being asked the right questions
- 57% reported their firm ‘cared’ with 58% saying that action to support was provided
Areas of Improvement
- Firms are still unable to effectively evidence how they monitor
- Some firms are not clear on what good look like
- Others have no measurement, escalation or improvement process
Some firms are still failing to give appropriate support to staff so that they can encourage disclosure and appropriate support
Future Focus
- If you haven’t there is an urgent need to define good outcomes
- Ensure your data is reliable and meaningful
- Encourage proactive customer disclosure
- Offer more staff training with vulnerability by design
- Provide appropriate, accessible channels to customers in vulnerable circumstances
- Test test test! to ensure there is a better understanding
Greater senior management focus and forums
How can GK help
Our team are experts in data integrity and regulatory reporting both as ad-hoc designs and via Bordeaux and Delegated Authority oversight solutions.
Over the last 3 years, GreenKite have assisted several Insurers and MGAs with their Vulnerability accuracy and understanding, improving the quality of their Product and Fair Value Assessments, Product Governance and Oversight Practices and generating market leading Consumer Duty Board Reports.
So, if you think your business could benefit from assurance and technical support in this area, please get in touch, and let GreenKite help you drive improvements in Conduct data and reporting.
Interested in reading the full FCA article? Click here!