The FCA has published a paper outlining its vision for well-functioning markets. Key to this is that the needs of all consumers, including vulnerable consumers are considered. The paper, ‘Approach to Consumers’, sets out the key drivers of potential vulnerability – health, life events, financial resilience and capability.
One way firms can help potentially vulnerable consumers is to ensure that their services are accessible and easy to use.
The FCA has stated that accessibility benefits everyone, not just the vulnerable, and it expects firms to ensure their communications are accessible to consumers by providing choice in how they communicate and ensuring that communications are designed in an inclusive way – for example, by considering the needs of visually impaired consumers.
The FCA is currently consulting on guidance for firms on the identification and treatment of vulnerable consumers. A paper is expected in early November 2018.
Meantime, as an early step to ensure that financial services firms work well for vulnerable consumers, the FCA has decided to revert to the original definition of vulnerability from Occasional Paper No 8, which defines a vulnerable consumer as: ‘someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’. The original paper dates from February2015 but provides useful guidance for firms in identifying and working well with vulnerable clients. Well worth a read.
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