Parallel advice from the FCA and SRA on the way vulnerable customers are treated

Today’s Wills & Probate reported last week that the Solicitors Regulation Authority (SRA) has identified the way vulnerable customers are treated by law firms to be a key risk within their Risk Outlook report 2015/2016.

This mirrors advice by the Financial Conduct Authority (FCA) who published an Occasional Paper on Vulnerable Customers in Financial Services in February this year. The paper was designed to provide lenders with guidance in respect of good practices in identifying and dealing with vulnerable customers.

In summary, the FCA found that: "Many consumers in vulnerable circumstances are not receiving fair treatment from their financial services providers. Whilst there are examples of good practice in some firms, some people find communicating with providers or accessing products difficult."

Key areas for companies to consider

  1. Ensure there is a high level policy in place dealing with vulnerable customers to ensure vulnerability is identified and a consistent approach across all operations.
  2. Ensure staff are aware of the policy and appropriate staff guidance and training is given to staff.
  3. Have you an efficient process in place for referring vulnerable customers to appropriate specialist teams?
  4. Is there clear, simple information and explanation in all your documentation and communications?
  5. Have you appropriate policies in place around data protection and affordability?
  6. Evaluate performance regularly, manage through relevant management information and periodically assess.

This risk is going to grow – according to the Alzheimer’s Society 1 in 14 people over 65 have dementia. Today’s Wills & Probate will continue to report on SRA Risk Outlooks which are published twice a year.

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