Some reaction to the latest update from the FCA on customers identifying themselves as being vulnerable, from Jonathan Barrett, CEO of Duty of Care Assessment firm, Comentis, who comments:
“We are disappointed to see that The FCA is putting the onus on the customer to self-report their vulnerability status. Not only is this alarming, but it’s misguided. The emphasis should be on the firms themselves to ensure good outcomes for their customers, not on the customer to self-report.
Let’s be clear here, relying on customers to be open about a potential vulnerability will never work. As evidenced in the FCA research, not only is there unfortunately a real stigma and sense of shame surrounding the prospect of being vulnerable, but it’s also entirely possible that the customer themselves might not even be aware that they’re at risk from a vulnerability in the first place.
We are surprised at the headline data that, “Just 4 in 10 vulnerable customers say they have disclosed their needs to their financial services provider”. This data is not reflected in reality – our data (from 175,000 real time assessments) shows the figure to be much lower.
On top of this, the wording itself is ambiguous (with customers’ needs being different to personal circumstances, which is the actual wording in the survey) and doesn’t reflect the messaging in the associated FCA report around identification.
We welcome further communications on this in the coming days to better emphasise the importance of active vulnerability identification and re-establish the onus on firms ensuring that all customer groups get equally good outcomes.”

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