Neil Tofield
The FCA’s expectations include:
- treat customers fairly
- ensure good outcomes
- demonstrate appropriate compliance
and, in particular, consider what this means in the context of vulnerable customers.
- Has your firm assessed its culture, strategy and objectives?
- Is appropriate monitoring of the treatment of vulnerable customers in place?
- Is the firm focused on achieving good outcomes?
- Can you demonstrate that responsibilities under the Duty have been met?
Conclusion
The FCA has made it clear that it intends to take an assertive approach and firms must be ready to meet the new requirements, with Boards (or equivalent management bodies) expected to take full responsibility for delivery, oversight and challenge. It’s important to note that firms must be prepared to share their plans with FCA supervisors and be prepared for their challenge too. Firms must consider the needs of customers in their target market specifically and focus on the customers they actually serve, not a hypothetical average. In addition, firms are expected to provide a level of support that meets consumers’ needs throughout their relationship with the firm. This means firms’ customer service should enable consumers to realise the benefits of the products and services they buy and ensure they are supported when they want to pursue their financial objectives.
