Vulnerable Customers

Who is a vulnerable customer?

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care.

Who do the requirements apply to?

The guidance applies to all firms to whom the Principles for Businesses apply. It is ‘just guidance’ but the Principles for Businesses apply to nearly all solo regulated firms, including (as of 2019) payment and e-money institutions. 

What are firms expected to do?

All firms are expected to understand the needs of vulnerable customers and make any changes required to meet the standards set by the regulator’s existing Principles for Businesses (Principles). 

Firms are expected to have in place robust policies, controls and training mechanisms to identify, assess, manage and interact with vulnerable customers.

How can we help?

We have partnered with subject matter experts who have extensive experience in supporting firms in identifying and supporting vulnerable consumers. We are working with firms in the form of a series of training workshops to perform a gap analysis and have a roadmap in place to implement a plan of action for firms to ensure they have the correct policies, procedures and training in place that ensure they are correctly identifying vulnerable customers and dealing with them fairly.