Consumer Duty / Vulnerable Customers

It’s all about data

Firms should now understand that at the heart of Consumer Duty is an expectation by the FCA that businesses develop more customer centric practices that result in improved customer outcomes.

Monitoring Customer Outcomes

Firms are required to monitor customer outcomes and intervene where they identify harm.

To achieve this, firms should monitor the activities they believe will lead to good outcomes and also monitor data that identifies whether these activities lead to good outcomes in practice.

The FCA recommend firms use several data sources to monitor outcomes, including customer feedback.

FWD specialise in providing Consumer Duty complaint customer outcomes surveys:

Attributes developed in consultation with the FCA.
Attributes that measure outcomes NOT satisfaction.
A digital first methodology that provides cost effective and representative sampling.
Accurate vulnerable Customer identification which enables firms to evidence outcomes of both vulnerable and non-vulnerable

Please click here to download the FWD Consumer Duty Vulnerable Customer Metro Bank Case Study

Please click here to download the Principality Case Study: Vulnerable Customer Understanding & Outcomes Monitoring

Vulnerability in the elephant in the room

Vulnerable customers are mentioned 106 times in the FCA guidance for firm, FG22/5 Consumer Duty. However, many firms have failed to incorporate vulnerable customers into their Duty data architecture.

If firms do not understand how prevalent vulnerability is amongst their customer base, they will be unable to develop informed vulnerable customer strategies. This in turn will mean they are unable to develop products, communications, and support that meet their needs and ultimately lead to good outcomes.

The FWD research team specialise in helping firms understand vulnerability:

We use the same approach as the FCA in their Financial Lives survey (this includes the questions asked, and the algorithm used to allocate respondents into the correct Vulnerability types).
Our approach has been developed in consultation with the FCA Insights team and extensively piloted.
A digital first methodology that provides cost effective and representative sampling.
Outputs that enable firms to confidently develop vulnerable customer strategies.
Our surveys also measure customer outcomes, so that firms can intervene where they identify any differences between outcomes for vulnerable and non-vulnerable customers.