UNDERSTANDING THE FCA’S VULNERABLE CUSTOMER GUIDANCE

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UNDERSTANDING THE FCA’S VULNERABLE CUSTOMER GUIDANCE

  • Charlotte Cherryman, Howard Taylor
  • Published: 27 August 2021


Customer vulnerability has proved an at times bewildering topic. Firms have grappled with how best to support potentially vulnerable customers, notably when it comes to practical considerations around data, operations and customer journeys, not to mention the challenges associated with designing effective and inclusive products. 

A key complicating factor is the sheer range of customers who could potentially be deemed vulnerable. Each such individual will have their own specific needs requiring varying and often complex solutions. While the industry and the regulators have made significant progress in acknowledging and beginning to cater to these differences, there is still much work to be done. 

In February 2021, the Financial Conduct Authority produced guidance on the fair treatment of vulnerable customers, describing it not as a one-off push but rather an ongoing area of focus. The regulator also stated that it would be checking firms’ policies, business models and cultures. Implementing the fair treatment of vulnerable customers at a policy level is a good start, but this alone may not be enough. 

In this Capco paper, we share: 

1. A summary of the FCA guidance 

2. How to identify vulnerable customers 

3. How to use customer data effectively

4. Ideas to help staff engage with vulnerable customers

5. How firms can approach a transformation programme. 

For more information about supporting vulnerable customers, please contact: 

Howard Taylor 
Capco Global Regulatory Delivery Lead
& Financial Inclusion Commissioner 

Charlotte Cherryman 
Senior Consultant, Capco UK