Vulnerability is a high-profile policy issue, which is receiving increasing regulatory, political and media attention. It is a fluid and complex area, tackling questions around the responsibility of both consumers and firms; access and exclusion; social inequality and individual capability.

It is also an area where UK Finance and our members are working proactively and with commitment to improve outcomes for customers in vulnerable circumstances.

In 2016 - in response to the FCA's 2015 Occasional Paper Consumer Vulnerability - we established the Financial Services Vulnerability Taskforce, chaired by Joanna Elson CEO of the Money Advice Trust. The Vulnerability Taskforce report in 2016 concluded with nine high-level principles and a series of recommendations which the financial services industry has actively sought to employ as a consistent framework for delivery.

High street banks and building societies and other financial services firms agreed to implement the new set of recommendations and principles under the Vulnerability Taskforce 

1. Sensitive, flexible response 
2. Effective access to support 
3. One-stop notice 
4. Specialist help available 
5. Easy for family and friends to support 
6. Scam protection 
7. Customer-focused reviews 
8. Industry alignment 
9. Inclusive regulation

Good progress has been made towards the identification and support of vulnerable customers in a range of product and service areas and, importantly, vulnerability policies are embedded within and across organisations - a clear indication of positive shifts in firm culture.

Working alongside consumer groups, government and other experts, as part of the industry's wider commitment to provide the best possible service for those who may need additional support, we have completed/or are in the process of completing industry wide work on delivering:

•  Principle 3 - One stop notice ? Bereavement Principles and Death Notification Service https://www.deathnotificationservice.co.uk enabling people to report the death of an individual to several major financial services providers at the same time.
• Principle 5 - ?Easy for friends and family to support? ? A code of practice designed to improve processes around the registration and use of legal instruments that can be used to enable third party access in England, Wales, Scotland and Northern Ireland; such as Power of Attorney, Court of Protection Orders to Appointees and Guardianship Orders. To further enable someone to help manage a customer's accounts alongside them, in March we designed a minimum standard for a third-party mandate which could apply across current account providers and a wider framework for supporting third party delegation for banking and savings products, including an outline for the mandate and the circumstances in which it could be applied.
• Principle 6 ? Scam protection ? The industry has implemented a range of measures to protect customers and target the unscrupulous fraudsters who prey on them. This includes the Banking Protocol, a scheme that allows bank branch staff to contact police if they suspect a customer is being scammed, which has so far prevented over £31m of fraud and led to 240 arrests.  We have also looked at non system detectable financial abuse and today have published a voluntary Financial Abuse Code of Practice which can help members build out their policies and provide  more consistent support to victims of financial or economic abuse.
• Review of progress to implementation ? The Taskforce intended that further assurance work would be undertaken to understand how firms had progressed with the implementation of the Taskforce Principles and recommendations. UK Finance, its members and the UK Finance Consumer Advisory Group commissioned the Lending Standards Board (LSB) to conduct this review launched earlier this week.

Over the past two to three years vulnerability has been a shifting debate.

As per the FCA's approach, we also recognise that consumer vulnerability is a dynamic state, which is affected by various factors including firm conduct and ability to leverage technology, innovation, data and cross-sector learnings towards a holistic view of a consumer's situation (or ?financial life?). Indeed the UK Finance Vulnerability Academy just launched in partnership with the Money Advice Trust seeks to enhance this type of thinking across membership.

At the same time, the Financial Conduct Authority is increasingly entrenching vulnerability as a conduct obligation - with higher expectations around the proactive identification and support of vulnerable customers and equally expectations around redress where firms have failed to do so. The highly individual nature of vulnerable circumstances does not naturally conclude in the same product, service or system adjustments, as the risk of harm to consumers will also be particular, rather than generic.

The marked shift in the regulator's thinking and approach raises opportunities but also a range of challenges for industry. Therefore, a pragmatic approach to implementation is needed, with targeted use. Industry needs a fair, clear and balanced framework of regulatory expectations of the sector towards consumers, which we very much hope to see aligned with the Taskforce recommendations and the dedication exhibited by our members in implementing those.