Although Vulnerability Guidance has been available since 2014, the implementation of the Consumer Duty in 2023 enshrined the fair treatment of vulnerable customers across 10 rules in the handbook which all regulated firms must follow to be able to identify and support vulnerable clients. However, the obstacles that exist in continuously recognising vulnerable clients and how to document actions taken, around the four drivers of vulnerability (Health issues, Life Issues, Individual’s resilience, Individual’s capability), are not clearly articulated by the regulator. The purpose of this working group is to assist members, client firms and the FCA in setting a centralised understanding of what is meant and also achievable in the interpretation of the guidance.

Key areas of focus

• Verify regulatory requirements around vulnerability are feasible and achievable.
• Improve understanding of FCA reporting requirements
• How to record additional cognitive vulnerabilities (resilience and capability)
• Establish the perimeter of client firm’s responsibilities
• Gain agreement with FCA of APCC thought leadership of all of the above  in setting common standards

Vulnerabilty Isn’t Just One Thing

APCC Thought Piece – Get Out of Jail Free

The Vulnerability working group meets monthly 10 times per year (not August or December), to discuss current issues and challenges in the industry, and look to engage with all relevant stakeholders. The group circulates minutes in relation to these meetings to the APCC membership. There is a vibrant program of guest speakers.

IF YOU WOULD LIKE TO TAKE PART IN THE DISCUSSION AS A MEMBER OR A GUEST SPEAKER AT THIS WORKING GROUP, PLEASE EMAIL MEMBERSHIP@APCC.ORG.UK