Vulnerable Customer Policy Template

Those with obligations under the FCA will know about their responsibilities to vulnerable customers. However, many other industries are now expecting firms to have policies and procedures in place to ensure that those who are vulnerable are dealt with in a fair, clear and transparent manner. Use our Vulnerable Customer Policy Template to comply with the FCA requirements.

The basis of any Vulnerable Customer Policy is to set controls and define objectives for effectively identifying, assessing and managing vulnerable customers. Defining what makes a customer vulnerable is not straightforward. Vulnerabilities can be fluid, temporary or permanent, meaning that firms must have flexibility in their vulnerable customer procedures.

Most businesses when developing their vulnerable customer awareness program focus on the well known vulnerabilties such as those who are deaf, blind, disabled or experiencing financial diffculties. However, the spectrum of vulnerabilities is extensive, ranging from bereavement, mental health issues and language barriers; through to those who may be unaware of what their options are or the consequences they may face.

The FCA provides guidance on the fair treatment of vulnerable customers, but does not go as far as having set rules for firms to follow. This often leads to mixed messages and differing approaches. Our vulnerable customers policy template is ready-to-use, but also fully customisable. Provided as a standalone document or included in our Vulnerable Customer & TCF Toolkit.

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