FCA has finalised its guidance on its expectations of firms in respect of vulnerable customers. The guidance stresses that FCA expects firms to ensure consumers have the appropriate degree of protection, and that key to this is assessing when they may be vulnerable. Firms need to understand the characteristics of vulnerability of their target market and customer base. If they do not, they will fail to ensure their staff, services and products meet the customers’ needs. The guidance gives significant detail on how firms should educate themselves on the characteristics of vulnerability and what harms and disadvantages they should be alert to. It focuses also on the necessary skills and capability of staff and the practical actions firms should take in terms of product and service design, customer service and communications. Finally, it sets out what firms should do to monitor and evaluate their actions. Throughout the guidance, FCA gives examples of what it would view as good and poor practice.
Alongside the guidance, FCA has published a MoU with the Equality and Human Rights Commission.