The FCA’s consultation paper on the fair treatment of vulnerable customers is a huge step in the right direction for the financial services industry. It encourages firms to realise that truly understanding their customers, appreciating that everyone could be vulnerable, enables success. Definitions of vulnerability are now widely accepted as broader than physical disabilities or low income, meaning facing into underlying, often hidden vulnerabilities becomes increasingly important.
As with most regulation, the flexibility allows firms to design products and services in a way that works for the individual and adheres to the regulation. But with flexibility comes ambiguity: Customers interact with financial services firms across different channels, different product sets and different providers. The ability for an organisation to collect joined up, cross-channel and cross-product customer information, to effectively deliver appropriate experiences and more importantly the right outcomes for vulnerable customer is critical.
Experience has shown us that firms are actively trying to provide support to their vulnerable customers. However, the new guidance is heavily focused on having customer-centric data and delivery methods which we know is a key challenge across the sector. Fundamentally changing from business-led to customer-led design requires a pan-business single customer view, and a shift to a customer-led governance processes.
For firms to meet their vulnerable customer regulatory obligations there is a healthy amount to consider, and areas we are actively supporting organisations on include:
- Reviewing existing channels, customer touchpoints and end to end processes to understand the vulnerable customer experience and identify focus areas for change
- Implementing inclusive product and service design principles into delivery approaches to make these changes, both tactically and strategically
- Making vulnerable customer data available across all customer touchpoints to enable a consistent experience, and using this information to monitor the impact of change
For more information on our previous research and blogs, please visit our vulnerable customer webpage, from here you can also access our online maturity assessment tool. This tool will help assess where your company is on the journey to delivering great outcomes for vulnerable customers.