Finalised Guidance has now been published, setting out the regulator’s view of what firms should do to comply with their obligations under the Principles and ensure they treat vulnerable customers fairly.
A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Because anyone can find themselves in vulnerable circumstances at any time, the Guidance is relevant to firms serving retail customers, including some business customers, regardless of the firm’s size or sector. It explains that to achieve good outcomes for vulnerable customers, firms should:
• understand the needs of their target market / customer base
• ensure their staff have the right skills and capability to recognise and respond to the needs of vulnerable customers
• respond to customer needs throughout product design, flexible customer service provision and communications
• monitor and assess whether they are meeting and responding to the needs of customers with characteristics of vulnerability and make improvements where this is not happening
Firms need to use their judgement to consider what each section of the Guidance means for them.