Dealing with vulnerable customers: The industry response

In early 2015 the Financial Conduct Authority (FCA) firmly put the issue of identifying and supporting vulnerable customers onto the boardroom table of all financial services businesses.

In its Occasional Paper No. 8 - Consumer Vulnerability - the FCA said research had found ?problems at every stage? and warned that, although there were no quick fixes, it wanted to see a more proactive approach from firms in the future. Four years on, is the industry rising to the challenge?

To gauge progress, we commissioned a major research study earlier this year that included in-depth interviews focusing on either strategic or operational insights from 19 major players across the UK life and pensions, lifetime mortgages and advisory markets. This was supplemented by quantitative research from more than 100 firms, including many advisory businesses of varying scale.

We wanted to understand how vulnerability is being interpreted by the industry, what response there has been in the four ?Rs? - how firms are choosing to recognise, record, respond, report - and in what ways the industry can work together on ideas and learn from other industries.

The full report shows a commendable depth and breadth of thinking and action being taken within our sector. The majority of firms are taking their vulnerability responsibilities very seriously, with only a minority (14 per cent) reporting that it had yet to reach board level.

That's not to suggest anyone can sit back and rest on their laurels. Clear from the research is that this is an ongoing journey, with firms currently spread out along the route at varying stages. Most have realised this is a multi-dimensional issue - the more you know, the more there is to know.

Half of the adult population is potentially vulnerable, according to FCA research from 2017,with higher levels among women (53 per cent) and the retired (64 per cent). Those on lower incomes and with lower qualifications are also more likely to be potentially vulnerable.

To get an idea of the scale of the job still in hand, the FCA's figures can be compared to recorded cases of vulnerability by firms in our discussions, which accounted for fewer  than five per cent of customers overall and fewer than one per cent for some individual firms.

The FCA saw the common components of vulnerability as health, life events such as redundancy, divorce or bereavement, lack of financial resilience and poor financial capability. In many cases it will be a combination of two or more.

Our research reveals firms are working hard to get the basics right - to identify and respond to vulnerable customers with greater support, knowledge and empathy. The complexities multiply when they move from dealing with the symptoms of an individual vulnerable customer, to truly embedding the requirements of all vulnerable customers within their day-to-day operations and longer-term strategies, including within all communications, digital journeys and future product design.

Success depends on consistency and co-operation. In reality, a vulnerable customer with a pension is likely to have a bank account, utility suppliers, insurance providers, investments and savings, etc. There is a strong need for the industry to develop a co-ordinated approach and most firms said they would welcome more cross-industry forums and initiatives to share best practice and innovation. There were also calls for more joined-up thinking with the government and the regulator.

Ultimately, policies need to focus on avoiding creating vulnerable customers in the first place, rather than tackling the vulnerabilities when they occur.

Copies of the research report are available to download here.