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Review of firms' treatment of customers in vulnerable circumstances

What has happened?

In March 2024, the FCA announced that it would conduct a review into how firms are acting to understand and respond to the needs of customers in vulnerable circumstances and that it would share its findings by the end of 2024. 

What are the key points?

The review is in line with the FCA’s 2021 commitment. It will look at firms’ understanding of consumer needs, the skills and capability of staff, product and service design, communications and customer service, and whether these support the fair treatment of customers in vulnerable circumstances, as well as at the outcomes consumers in vulnerable circumstances receive and whether they are as good as the outcomes of other consumers.

The FCA will conduct consumer research in this area as well as gathering information from firms and consumer representatives to make this assessment.

Rather than involving a separate piece of work focused solely on age related issues, as suggested in 2017, the review will now look more broadly at how firms treat customers, including older customers, in vulnerable circumstances.

How can we help you? 

Thistle Initiatives has supported firms for over 10 years as a trusted compliance and regulatory advisor. In addition to assisting firms as-and-when, our team of specialists can serve as your right hand in meeting and complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your vulnerable customer arrangements, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to

For more information on what the FCA expects from firms, they can review FCA information covering the Guidance for firms on the fair treatment of vulnerable customers, from February 2021, and the Consumer Duty.