The banking and finance industry is committed to looking after every customer, especially those in vulnerable circumstances. The Financial Conduct Authority's (FCA) Guidance Consultation GC19/3: Guidance for firms on the fair treatment of vulnerable customers provides additional clarity on the FCA's expectations and continues the narrative on the importance of vulnerability, as set out in Occasional Paper 8 and the Approach to Consumers.

Over the last five years, the industry has invested significant resources in delivering better outcomes for vulnerable and disabled customers. As part of this continuous improvement approach, UK Finance worked with Joanna Elson OBE, CEO of the Money Advice Trust, leading charities and regulators to develop the Vulnerability Task Force Principles. The draft Guidance builds on this work and it is pleasing to see that many of the Task Force Principles have been integrated into the 27 requirements specified in the consultation document.

UK Finance, in its response to the consultation, welcomes the Guidance. Delivering a consistently high standard of service to the most vulnerable members of society is not only the right thing to do, but also speak to the ethos and values that firms aspire to. The industry is committed to sharing best practice, driving forward improvements in customer outcomes and demonstrating that they are delivering the 'step change? that the FCA requires. Developing a common understanding of the Guidance is an important next step. Therefore, our response seeks clarification of the FCA's expectations where needed and provides examples where more detail would be welcomed.

In the second stage of the consultation, we ask the FCA to provide further detail on:

• their supervisory expectations when assessing whether firms are treating vulnerable customers fairly
• how firms may satisfy their regulatory obligations under both the General Data Protection Regulation (GDPR) and the expectations set in the draft Guidance
• a timeline and implementation period that reflects that all firms will have a different starting point
• alignment with the Financial Ombudsman Service on the aims of the Guidance.

UK Finance will work with the FCA, members, and other key stakeholders (including regulators and consumer advisory groups) to develop a more detailed understanding of what ?good looks like?. UK Finance commits to supporting our members by:

• working with them to share best practice and develop a summary of actions that firms can take to embed fair treatment of vulnerable customers in all parts of their business
• considering changes, where appropriate, to the Vulnerability Task Force Principles to ensure alignment with the Guidance
• continuing to discuss how firms should record vulnerability under GDPR with the Information Commissioner's Office (and facilitate discussion between the regulators and members if this would be helpful)

We look forward to working closely with the FCA as the Guidance develops and we offer support to the FCA and the industry to ensure the delivery of consistent standards across the sector and better outcomes for vulnerable customers.

Whilst firms are making progress to address the expectations of the regulator, many firms recognise the need to improve their internal knowledge and understanding of the key issues facing their colleagues to ensure customers are treated fairly and appropriately. In response to this, UK Finance and the Money Advice Trust have launched the Vulnerability Academy. Click here to learn more.