CAS welcomes the FCA's commitment to vulnerable consumers and the guidance they have published to help firms understand their obligations.
We think that firms can do better at working with vulnerable consumers by ensuring that:
- Inclusivity is built into their culture, product design, sales, communications and processes.
- Vulnerable customers are able to share information with them and that this is correctly and appropriately recorded (in line with data protection principles) so that people do not have to continually tell the firm about their vulnerability. Furthermore that this information is reviewed so that if the customer’s circumstances change, the service is still provided in a way appropriate to their needs.
- If a particular product is exacerbating vulnerability, then they must offer extra support and advice to vulnerable consumers (or refer them to independent advice) to help them decide whether the product is right for them, before they take on said product.
- They respond flexibly to accommodate vulnerable consumers (and the people that are helping them) and do not bind their front line staff in inflexible policies and procedures.