PRZEMEK DE SKUBA | Senior Consultant, Capco
BIANCA GABELLINI | Consultant, Capco
JESSICA TAYLOR | Consultant, Capco

Customer vulnerability is one of the key concerns of the Consumer Duty regulation, a very welcome ESG-aligned enhancement of financial institutions’ governance. Adherence to the regulation requires a clear focus on data collection that helps lenders manage the impact of consumer vulnerabilities without imposing penalties or resulting in a negative
impact on clients. 

There are two parts of the problem that need to be addressed: firstly, how to capture vulnerability data by encouraging clients/consumers to voluntarily submit the information (the behavioral aspect) and secondly, how to technically capture, manage, and store this data to ensure compliance with the Consumer Duty regulation. 

This article considers both problems and reviews the tools from behavioral science that can encourage customer disclosure and two key technology solutions (data lakes and blockchain) to comply with the capture, management, and storage of data whilst remaining GDPR compliant and fully aligned to the objective of voluntary submission of information regarding vulnerabilities by clients/consumers.