Although the FCA has recently softened its tone, in line with the Government’s growth agenda for the economy, it has been at pains to point out that growth and competition is a secondary objective for the FCA, whereas consumer protection is still a primary objective.
One area where this is apparent is the FCA’s ongoing work on vulnerable customers, which is closely aligned to the Consumer Duty.
It recently published a report on delivering good outcomes for customers in vulnerable circumstances together with research that it had conducted in this area.
It found that just 4 in 10 vulnerable customers said they had disclosed their needs to their financial services provider, but the FCA found that for those customers that do open up about their vulnerability, then they tend to have better experiences.
In terms of supporting customers in vulnerable circumstances, the FCA recommends that firms:
Use data effectively to monitor outcomes
Offer flexible and tailored support
Deliver clear, timely customer communications
Consider vulnerability in product and service design
These are all areas that ITC has considered and built into the customer journey through recording on APEX, as well as providing training modules for your staff. This should ensure that all customers receive good outcomes.
The FCA’s view is that the financial services industry is not doing enough to identify vulnerable customers, it is therefore very important to record customer vulnerability via the Customer Support Form in APEX, whilst recognising that this can sometimes be temporary depending on the customer’s circumstances.
Potential vulnerability should be considered at every contact point with the customer, from Qualification through to Handover.