Treating vulnerable customers fairly

The following Financial Services practice note provides comprehensive and up to date legal information covering:

  • Treating vulnerable customers fairly
  • How was the guidance developed?
  • Introduction to the finalised guidance—FG21/1
  • Who are vulnerable customers?
  • Complying with the Principles for Business—what should firms do?
  • Understanding the needs of vulnerable customers
  • Skills and capacity of staff
  • Embedding the fair treatment of vulnerable consumers across the workforce
  • Ensuring frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability
  • Offering practical and emotional support to frontline staff dealing with vulnerable consumers
  • More...

Treating vulnerable customers fairly

This Practice Note looks at the Financial Conduct Authority’s (FCA) final guidance (FG21/1), which clarifies the FCA’s expectations of firms on the fair treatment of vulnerable customers. The guidance, published on 23 February 2021, was introduced with the aim of driving improvements in the way firms treat vulnerable consumers so that they are consistently able to achieve outcomes that are as good as those for other consumers. The Practice Note considers the background to and development of FG21/1, the detailed content of the finalised guidance, and related developments.

How was the guidance developed?

In July 2018, the FCA published its Approach to Consumers document, which aimed to address concerns raised in feedback to the FCA’s consultation on the topic. The Approach to Consumers document sets out the FCA’s vision for well-functioning markets for consumers and the conditions it wants to see to achieve this, as well as explaining how the FCA uses its powers and tools to protect consumers and its commitment to review and adapt these to ensure the greatest impact is achieved for consumers. In the document, the FCA defined a ‘vulnerable consumer’ as someone whose circumstances make them especially vulnerable to harm if a firm has not acted with appropriate levels of care, such as resolving their complaint promptly and fairly. It listed circumstances that could cause a consumer to

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