Consumer Duty requires firms to consider whether different groups of customers are experiencing different outcomes, including those with characteristics of vulnerability. This goes beyond identifying vulnerable customers and requires firms to assess whether outcomes for these customers are as good as those for others.
Firms should have processes in place to identify potential vulnerability, whether temporary or permanent, and to consider how this may affect a customer’s ability to engage with products and services. This consideration should be clearly reflected within the annual Consumer Duty assessment.
Where a firm identifies that a vulnerable customer, or a particular customer group, has received a poor outcome, this should be fully investigated. Appropriate action should then be taken to address the issue, mitigate any risk of harm, and prevent similar outcomes from occurring in the future.
By actively considering vulnerability and responding appropriately where concerns arise, firms can demonstrate a strong commitment to fairness, good faith and positive outcomes for all customers, in line with the FCA’s expectations.
