The FCA has published a statement regarding consumer protection and ongoing compliance during the Coronavirus (Covid-19) pandemic. The financial services and consumer credit regulator has emphasised that they still expect regulated firms to demonstrate a high-level of compliance when it comes to treating customers fairly and dealing with vulnerable customers, especially as the ongoing situation is likely to cause additional financial pressure on many consumers.
Organisations regulated by the FCA must ensure that their TCF policy and controls are up to date and effective, and should review their existing vulnerable customer policy and measures to determine if they are adequate given the strain that many consumers could feel at this difficult time.
Those in direct consumer credit sectors (i.e. mortgage lenders, credit providers, lenders etc) must be extra vigilant and considerate when dealing with consumers who have been affected by the Coronavirus situation and should ensure that they have robust and effective policies and controls in place.
Policies & Controls to Review: –
- Treating Customers Fairly Policy
- Vulnerable Customers Policy
- Arrears & Default Policy
- Affordability & Creditworthiness Policy
- Affordability Assessments
- Income & Expenditure Forms
- Financial Difficulties Policy
- Business Continuity Plan
- Information Security Programs (i.e. Remote Access & Working From Home Policies)
The FCA noted in their Covid-19 statement that “[they] are working closely with firms to ensure markets continue to work well for consumers [and] continue to make clear that firms must treat customers fairly and consider the needs of those potentially affected by the impact of coronavirus.”
The FCA has also advised that they expect organisations to assess their preparedness and review business continuity plans to ensure that they meet the demands and obligations of likely stresses such as staff shortages; lack of resources; reduced supplies etc.