As with all long journeys, where to start and getting started is often a difficult step – particularly where not all organisations see this as a top priority.
I see two levels of change. First is the culture of the advice company.
Embedding the need for everyone in the organisation to consider how their role and function impacts vulnerable customers and how they logically need to adapt to ensure the appropriate support and considerations are in place.
Changing culture is never easy, but vulnerability requires a rebrand from its external focus on clients. It is people who are vulnerable, and that includes us and our friends, contacts and colleagues in the financial services industry.
While we work in the sector, we are all customers of financial services too. I am also willing to bet that over the past few months, we, or someone we know, have all met the criteria of vulnerability and found interaction with financial services difficult.
We are therefore in a great position to tap into people’s empathy around how we would like financial services to work better, particularly when the need for that extra bit of help and support is in play.
The second level is more practical, driven by people, process and technology.
How do you identify all the changes needed throughout an organisation, especially a large one, and make them happen? That is a complex question for any transformation activity, and one that requires a comprehensive model of the business to ensure nothing gets forgotten.
The regulator acknowledges that lots of good work has been done, but not in all companies, which has led to customer harm. I have previously stated this case but, to date, the good work appears focused on specific use cases, or scenarios.
The FCA wants companies to turn their attention to being robust in response to the broad spectrum of vulnerability they will encounter.
The issue of inconsistency remains. No minimum standard will be prescribed, but the FCA remains concerned that experiences (same situation, different treatment) continue to be mixed, which represents something of a dichotomy.
The industry will need to find a way to collaborate to achieve some basis for consistency.
I personally found the 21 in-depth case studies the FCA has shared to be a useful source. While they cannot possibly cover every eventuality, they do provide the basis to extract principles of behaviour in certain cases that can be extrapolated and applied.
The financial lives survey on vulnerability offers interesting insight. Something that became implicit is how dealing with one vulnerability driver can prompt others, for example, a health-related condition could well cause the customer to be unable to work and impact their financial capacity – 16 per cent of consumers display two of the four drivers.
