The FCA have recently published their guidance on the fair treatment of vulnerable customers. The FCA expect firms to treat customers fairly, and to exercise particular care with vulnerable consumers.
When consumers are in vulnerable circumstances, it may affect the way they engage with financial services. Vulnerable consumers may be significantly less able to represent their own interests and they may have different needs that negatively impact their decision making.
You can watch a video here that explains more: http://y7a5w.videomarketingplatform.co/vulnerability-guidance-animation-1
To support the process, four new questions have been added to the Applicant(s) details in OMS to help you identify whether an Applicant is vulnerable.
Once identified, we need to establish and document whether any changes are required to the sales process, as a result. For example, if a customer is blind or partially sighted, one consideration would be whether it was beneficial to present all the relevant documentation in braille or do they have the support of a sighted person to assist. The key question we have to answer is: are we treating this customer fairly? Will we achieve the same outcome for this partially sighted customer as we would for a customer with perfect vision?
If you are using your own fact finds to gather data initially from clients, you should ensure the questions in OMS are added to your own template.
We will be providing more guidance on the subject in due course and also be creating a course in the Connect Learning Management System, but if you have any questions in the meantime, please direct them to the Compliance team.