Supporting vulnerable clients

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• The FCA’s Finalised Guidance (FG21/1)
• FCA focus areas for vulnerable customers
• Our top tips for adviser firms and case studies

The FCA have issued guidance to firms around the fair treatment of vulnerable customers, to ensure they receive outcomes as good as other customers and get consistently fair treatment. You can read more about the FCA’s expectations in our high-level summary of the regulator’s guidance to firms.

Summary of the FCA’s Finalised Guidance (FG21/1)

In short, the FCA’s guidance falls in the following areas:

• Understanding the needs of vulnerable customers in your target market/customer base
• Making sure staff have the right skills and capability to recognise and respond to the needs of vulnerable customers
• Responding to customer needs throughout product design, flexible customer service provision and communications
• Monitoring and assessing whether you are meeting and responding to the needs of customers with characteristics of vulnerability, and making improvements where this is not happening

With the introduction of the Consumer Duty regulations, which overlap and enhance the FCA’s expectations on how all customers are treated, you may wish to familiarise yourselves with the regulator’s guidelines.

You can also take a look at our Consumer Duty Hub which includes our guide to the Consumer Duty, a webinar which discusses the key changes you need to make plus other data to support this regulatory change.

The FCA require that all firms ensure the fair treatment of customers in vulnerable circumstances. As such, they have suggested some key areas to focus on. Below we have detailed how we approach these areas and include suggestions on how you can support your clients:

Understanding the needs of vulnerable customers

At Fidelity
We use data like the FCA’s Financial Lives survey to inform the nature and extent of vulnerabilities present in our customer base. We can then understand what additional needs some of our customers may require. We encourage customers to disclose their circumstances to us so that we can provide additional support where needed.

Adviser firm
We suggest identifying your target market and considering what support needs some of your customers may have. Some vulnerabilities may be more likely in groups of customers that share characteristics. For example, older customer segments will include a higher proportion of experienced investors but also more customers with age-related health conditions. Younger customer segments will almost exclusively prefer digital options but will include a higher proportion of inexperienced investors.

Skills and capability of staff

At Fidelity
All of our colleagues, irrespective of whether they are client facing or not, have attended training on supporting customers in vulnerable situations. All client-facing colleagues have been through enhanced training. We also have dedicated vulnerable customer champions to help support or take over more complex calls as necessary.

Adviser firm
You may wish to think about the following:

• Ensuring your colleagues are fully trained on what it means to be a vulnerable customer
• Considering how you respond to the needs of vulnerable customers
• Having vulnerable customer champions in place

Product and service design

At Fidelity
All of our products have been assessed against a value-for-money framework that considers the impact on customers in vulnerable situations applicable to the target market. Products and associated literature and other content are checked to be clear, concise and in plain easy-to-understand language, paying attention to anything that could be deemed as difficult for vulnerable customers to digest, and changed as necessary.
We regularly work with our customers in focus groups when designing new products and important communications.
We work with internal and external subject matter experts to understand what is needed and adapt as necessary. 

Adviser firm
Consider any specific needs of vulnerable customers when recommending any product or service, particularly in terms of their understanding.  You should look to evidence how you are supporting vulnerabilities.

Customer service

At Fidelity
Our vulnerable customer champions sit within our Client Services and Operational teams to act swiftly to support vulnerable customers and colleagues as necessary. We have updated our technology to be able to identify vulnerable customers so that their needs are met as soon as they make contact with us. We can adapt our service offering, service provision and communications as needed.

Adviser firm
We suggest that you ensure a customer-centric culture is in place that supports all customers and their needs. All staff should have sufficient training. For example, consider offering a safe space in branch where clients feel comfortable to talk about any vulnerability they may be experiencing.

Communications

At Fidelity
We endeavour to make all of our content easy to follow in plain simple text avoiding layout issues that could make them hard to digest and understand. We are committed to removing technical jargon.
Our communications can be accessed in a wide variety of ways including large print, braille and audio CD. We can also provide documents to help our clients who are neurodiverse and benefit from documents being formatted on a different background colour, with tinted overlays, colour text and various fonts and size.

Adviser firm
We recommend communicating as clearly and as concisely as possible. Summarise any technical documents so that the key points are clear and understood. Try using the existing relationship with the customer to enhance your understanding of their needs.

Monitoring and evaluation

At Fidelity
Our vulnerable customer champions meet on a monthly basis to evaluate any contact made by a vulnerable customer to understand what went well and what lessons can be learnt. These are then implemented across the business as necessary. Support is in place for colleagues dealing with the most sensitive cases.
Regular training is held to make sure knowledge stays up to date and a customer-centric culture permeates all areas of our business.

Adviser firm
We suggest reviewing your policy and procedures on a regular basis. Be able to identify learning processes and implementation of new ways of working as necessary, and record as appropriate.

• Have a policy in place
• Work with external subject matter experts and data (like the FCA’s Financial Lives survey) to better understand some of the challenges that customers could face
• Ensure staff have the relevant training and support to recognise and respond to the needs of customers as needed and make sure this is provided regularly
• Produce and review management information on the outcomes you are delivering for customers in vulnerable situations and implement action points as necessary
• Have clear lines of accountability for senior leaders and be able to demonstrate what your firm has implemented when considering vulnerable customers
• Embed fair treatment of customers across all business areas
• Consider vulnerability in the context of people, not just customers – colleagues and key contacts with clients can also be in similar vulnerable situations that require some form of additional consideration