Working together to support vulnerable customers

• 31 March 2022
• Blog | Professionalism and Ethics | Consumer Duty | Blog

More than 33% of financial services sector professionals consider themselves to be at least ‘somewhat’ vulnerable, according to a recent survey from the Chartered Body Alliance. Chartered Banker explores the results.

The Chartered Body Alliance, a joint initiative by the Chartered Insurance Institute (CII), Chartered Institute for Securities & Investment (CISI) and the Chartered Banker Institute, conducted research into the treatment of customers in vulnerable circumstances. The survey was taken between 4 August and 8 September 2021, with a total of 1,537 responses, largely drawn from the CISI Member portal and the Chartered Banker Institute.

Nearly 25% of respondents worked in investment management, private and wealth management, or retail branch banking, with more than 14% classifying themselves as ‘somewhat vulnerable’ and more than 18% admitting they were ‘vulnerable’ themselves.

The survey follows the Financial Conduct Authority’s (FCA’s) publication Guidance for firms on the fair treatment of vulnerable customers and asked respondents a number of questions around their recent experiences with customers in that category and how they evaluated their ability to support them or those in a similar situation.

Over the 12 months preceding the survey, 61% said they had either directly or indirectly supported a vulnerable customer, with 75% saying they had discussed the issues surrounding such customers either frequently or on occasion.

On the front line

An encouraging 74% of participants said they had no concerns regarding the implementation of FCA guidelines, despite only 58% having received formal, structured training on the matter and just a little over half of those (51%) having undertaken the training in the past six months.

The new guidelines were published to “drive improvements in the way firms treat vulnerable consumers and bring about a practical shift in firms’ actions and behaviour”. The recommendations have the overall aim of enabling vulnerable customers to experience outcomes that are as positive for them as for all others.

The FCA publication claims that, although many firms are making great progress in their support of vulnerable customers, they (the firms) have seen several examples where customers’ needs have not been considered, leading to harm.

The FCA defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care”.

CISI CEO Simon Culhane, Chartered FCSI, said: “Our report shows that the majority of professionals are seriously addressing their duties and responsibilities in this area.”

More than 80% of respondents claimed their employer has taken steps to “implement a work environment that embeds fair treatment of vulnerable customers”. However, Culhane believes that there is still more to be done, citing some of the examples of bad practice outlined by participants.

Some 556 respondents were able to give anonymous examples of poor practice they had witnessed in their own workplace, which included pushy salespeople, elderly customers being directed to online complaints forms, overuse of automation due to lack of available telephone support, and a general lack of empathy and sensitivity towards disabled and bereaved customers. Culhane insists these issues should be a priority for the sector.

“Lack of empathy, overuse of automation and poor communication are themes we must address. The FCA Consumer Duty proposals specifically state that regulated firms should ‘put themselves in the shoes of others’.

“We acknowledge the gaps in knowledge, skills and behaviour which this survey has highlighted. We will start this process by producing a Chartered Body Alliance toolkit and a series of events for 2022, with roundtables for well-being leads in member firms, to open the discussion on this survey outcome.”

The Institute and CISI are holding a live, interactive discussion on Tuesday 1 March, during which we will present a series of dilemmas to an expert panel. For more information or to book, please visit: charteredbanker.com/events.

A culture of care

Respondents were also asked to give an overall rating of several aspects of their firms’ customer life cycle, regarding vulnerable customers. Although ‘acting in good faith’ was ranked highest, with the most ‘excellent’ ratings, ‘communication’ was the lowest scored, perhaps suggesting a gap between good intentions and results.

Although the FCA publishes a very clear set of principles when it comes to its expectations around the treatment of vulnerable customers, implementing effective policies to achieve these standards in a large organisation is perhaps more challenging.

One participant commented: “While I understand and support the drive to further develop client assessment of vulnerability, this is stepping into the realms of psychological evaluation and behaviour, an area that the vast majority of advisers will not be prepared or qualified to assess”.

Most participants (72%) felt they had both a personal and professional responsibility in the safeguarding of vulnerable customers.

Identifying the issue

When respondents were asked how confident they would be in identifying a customer in vulnerable circumstances, answers averaged 76% – an interestingly lower percentage than the level of confidence in being able to deal with those customers effectively (77%), after having identified them.

With nearly 25% of respondents saying they wouldn’t be able to identify a vulnerable customer in the first instance, it’s not surprising that the research supports the FCA’s claim that firms, while having made good progress, still have a lot of work to do.

“This research underlines how important it is for us all to have an inclusive approach to all customers, and not treat vulnerability as an ‘add on’ that applies only to a minority.”

This may also be down to a discrepancy in definition, as only 65% of respondents claimed that their firm had a formal definition of vulnerable customers and only 55% said that definition was aligned with the FCA’s.

Next steps

The biggest challenges outlined from these results seem to centre around communication. Communication with vulnerable customers was the lowest-ranked aspect of the customer life cycle, while lack of a clear and concise definition of what a vulnerable customer is, and what policies are in place for supporting them, point to a lack of communication between executive management and frontline staff.

The results show that 20% of firms don’t have policies and procedures in place for supporting vulnerable customers, however it is possible that these policies exist and simply haven’t been communicated effectively to all employees. Considering only a minority had received any training on the matter in the six months leading up to the survey (and 21% had not received any training in the past year), there is a strong possibility that advances are being made at an executive decision-making level, but failing to filter down to those on the front line.

Simon Thompson, Former Chief Executive, Chartered Banker Institute, welcomed the report’s findings and results, which he says, “give us some great insights into how our members feel about the treatment of their customers in vulnerable circumstances”.

On the question of how the industry is addressing the issues surrounding vulnerability, through what are still extremely challenging times, Thompson went on to say: “Over the past 18 months, we’ve all faced the very real challenges of supporting customers, colleagues, loved ones – and ourselves – through the series of challenges presented by COVID. Yet throughout this difficult period, banks and bankers – and the members of the Chartered Body Alliance in particular – have continued to play key roles helping to rebuild businesses, communities and personal finances.

“During this period, we offered a number of free resources to assist our members in their day-to-day roles in dealing with vulnerable customers; but as these findings reveal, more needs to be done, and we encourage all employers to work with us to step up the training required, while also considering their employees’ well-being needs.”

Expanding support

On the issue of the surprising number of participants who classified themselves as vulnerable, Culhane commented: “The fact that 33% of respondents working in financial services also considered themselves vulnerable within the past 12 months has emphasised the importance of looking after our own member practitioners. We will be examining how we can expand the CISI mental health portal in particular to further support financial services professionals in this respect.”

Sian Fisher, CEO, CII, highlighted that the high number of participants classifying themselves as vulnerable is an indication of how fundamental vulnerability is to inclusiveness.

“If we think we are going to go through our whole lives avoiding a time when we fit the definition of ‘vulnerable’, we are kidding ourselves.

“Financial circumstances, ill health, disability and life events all mean that we are almost certain to go through a period in our lives when we are vulnerable. This research underlines how important it is for us all to have an inclusive approach to all customers, and not treat vulnerability as an ‘add on’ that applies only to a minority.”

The FCA also found a larger number of people classifying themselves as financially vulnerable through its Financial Lives Coronavirus Panel Survey in October, with 53% of adults displaying a characteristic of vulnerability. This was an increase of more than three million since a previous survey in February 2020 and included many people classifying themselves with multiple characteristics of vulnerability.