As the treatment of vulnerable customers comes under the FCA’s spotlight, we look at some of the common issues vulnerable customers face in their dealings with the financial services industry and the improvements firms can make.
Mr Alpha has been his father’s legal carer for eight years and was able to arrange third party access to his bank account to help him manage his father’s financial affairs. Despite this arrangement, staff have refused to serve him on a number of occasions and insisted that his father come into the branch to arrange things directly, despite Mr Alpha explaining the seriousness of his father’s condition.
The FCA found evidence of a gap between the head office policies in place and their practical implementation by frontline staff, as in the situation above. Getting vulnerable customers the positive outcomes they need relies heavily on the actions of front-line staff, so firms should be closely monitoring the implementation and ongoing adherence to policies and procedures, as well as gaining consistent and regular feedback from vulnerable customers to ensure their needs have been accommodated and any gaps can be identified.
When Mrs Beta’s husband died, she informed her home insurance provider immediately and provided a copy of the death certificate so his name could be removed from the account. Weeks later she was still letters addressed to her deceased husband advertising the insurer’s latest deals and products.
Where applicable, disclosure of vulnerable circumstances should be communicated to all relevant departments of the firm and not just remain within the department which received the initial disclosure. At times of increased stress, having to repeatedly inform a company, or inform numerous departments of their circumstances can be detrimental to a vulnerable customer’s wellbeing.
Miss Delta is partially blind and also suffers from a long-term condition. She encountered issues when trying to open a savings account as she does not hold a passport or driving licence. Although she holds other, non-standard, identification documents, she was unable to open an account because she could not provide the documents specified on the bank’s account opening policy.
To accommodate the needs of vulnerable customers, a firm’s policies should be provide enough flexibility to accommodate those in non-standard circumstances, such as those of Miss Delta. Policies and training should also empower employees to act with appropriate discretion when dealing with vulnerable customers.
These are just some of the scenarios uncovered during the FCA’s research into the fair treatment of vulnerable customers. Vulnerability is a very broad issue and can affect people in very different ways, so a firm’s approach should be flexible and empower staff to act with discretion to achieve the most appropriate outcome for the customer.