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FCA Publication: Consumer Duty – information for firms


The FCA has updated its previous guidance on the Consumer Duty, specifically on the requirements for firm to identify customers with characteristics of vulnerability.  

As part of the Consumer Duty, the FCA expects firms to be able to identify customers in vulnerable circumstances, understand their needs, and act to meet those needs where necessary. This would help firms reach good outcomes for their customers, and the FCA expects firms to actively encourage customers to share information around their needs or circumstances, where this is relevant.  

The FCA expects firms to: 

  • set up systems and processes that enable customers to disclose their needs 
  • support staff to actively identify signs of vulnerability, for instance through training and resources 

Where firms interact with customers through digital channels, the FCA recommends utilising tools, such as text boxes or chatbots, which would allow customers to share information around their needs.  

Where firms communicate face-to-face or over the phone, the FCA expects firms to support staff to be able to recognise observable signs of vulnerability and encourage customers to openly discuss their specific needs.  

FCA expectations are that this would allow firms to capture the relevant information around any characteristics of vulnerability or communication needs, which would then allow firms to align their service to meet the needs of its customers. 

Identifying and supporting customers with vulnerabilities is a big topic at the FCA currently, and the FCA recently fined HSBC UK Bank plc £6,280,100 for deficiencies in HSBC’s policies and procedures, its staff training, and the measures it had in place to identify and address unfair customer treatment in 2017-2018. This focus will only be more prominent now with the advent of the Consumer Duty. 

Thistle’s in-house experts are able to offer support and guidance for firms that are currently in the process of incorporating the Consumer Duty into their business model, including providing template Consumer Duty and Vulnerable Customers policy documents.  

Thistle is also able to provide further support regarding the upcoming requirements coming into effect around the Consumer Duty, such as the review of closed products and the requirement to conduct a Consumer Duty Board Report – for which we have a template document to assist firms.