Embedding fair treatment of vulnerable customers

In a more paternalistic regulatory climate, where large numbers of consumers qualify as vulnerable, the Financial Conduct Authority’s recent guidance consultation goes into more detail on the issue than ever. “The more one talks about vulnerability, the greater is the likelihood of the situation improving,” says Adam Samuel.

Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted atadamsamuel@aol.com.For links to where you can buy the second edition of ‘Consumer Financial Services Complaints and Compensation’, see www.adamsamuel.com/book.

An introduction to vulnerability

The handling of vulnerable customers has become one of the hot topics of the age. Increased automation of many aspects of financial services has created an environment suited to standardised customers. It does not work as well for people without the technical ability, mental strength and financial solidity that the perceived average person has. Much of the discussion about vulnerability stems from the disappearance of the all-knowing bank manager who welcomed people into his or her office for a chat when things became difficult. Equally, with the increasing use of non-advised investment and insurance channels, there may have been a loss of the personalised touch. In a more distanced environment, vulnerability starts to become a serious issue or maybe it always was but remained concealed from view.