vulnerableIn their 2020/21 business plan, the FCA advised that vulnerability continued to be an important part of their work and that they had an aim of ‘ensuring that the most vulnerable are protected’. Following on from their initial guidance consultation published in July 2019 on the fair treatment of vulnerable customers (GC19/3), the FCA have now opened GC20/3 which discusses the feedback received on GC19/3 and seeks views on their updated draft guidance (consultation closes 30/09/2020 with the finalised guidance being published in Winter 2020).

Within their draft guidance the FCA have noted that firms should ‘create an internal vulnerability policy that includes information on the vulnerabilities present, or likely to be present, in the firm’s target market. Formalising this information in a policy can help to raise awareness throughout the firm.’ The FCA also identify drivers of vulnerability (including health, life events and capability), as well as factors that can lead to potential harm for vulnerable customers and emphasize how important employee training is when it comes to protecting those who are identified as vulnerable.

Vulnerable Customer Documents

Having robust policies, controls and training mechanisms in place for identifying, assessing, managing and interacting with vulnerable customers is an essential business practice and one of the Principles for Business set out by the regulator.

Know Your Compliance Limited offer market leading policies, templates and training packages dedicated to vulnerable customer awareness that can help firms to meet the requirements set by the FCA and other relevant governing bodies.

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