The Financial Conduct Authority (FCA) definition of a vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.
What is a Vulnerable Customer?
Ofgem defines a vulnerable customer as when a consumer’s personal circumstances and characteristics combine with aspects of the market to create situations where he or she is:
significantly less able than a typical domestic consumer to protect or represent his or her interests; and/or
significantly more likely than a typical domestic consumer to suffer detriment or that detriment is likely to be more substantial
As studies have shown, most people don’t identify themselves as being vulnerable, which makes it difficult to recognise when people need additional support and care. Understanding whether a vulnerability is transient, recurring, or permanent also makes it difficult to define when customers are in need of aid.
Drivers of vulnerability in customers
There are four key drivers of vulnerability, as defined by the FCA:
- Health: This refers to disabilities or short-long term illnesses that may affect an individual’s ability to carry out day-to-day activities
- Life events: This touches on major life events such as death, a job loss, or a relationship breakdown i.e. divorce
- Resilience: This makes reference to the low ability of an individual to withstand financial or emotional shocks
- Capability: This alludes to limited knowledge of financial matters or having low confidence in managing money. This also includes low capability in areas such as digital or literacy skills
Regulatory bodies want to ensure that firms protect their vulnerable customers and provide them with a level of care appropriate for their needs. This might be using alternative communication channels because a disabled consumer isn’t able to get to a branch or a blind customer might request braille.
To learn about how we can help you better recognise, record and respond to all customer vulnerabilities, visit our customer vulnerability page.
