Vulnerable Customers

Session 1: Introduction – The Regulatory Position

Vulnerable customer training introduces the key regulatory standards and best practices for effectively identifying, engaging with and supporting vulnerable customers. Sessions cover:

• Occasional Paper 8

• The FCA definition of a vulnerable customer

• GC19/3 and GC20/3: Guidance for firms on the fair treatment of individuals in vulnerable circumstances

• Assessing the March 2020 TISA Vulnerability Conference speech by the FCA’s Director of Consumer and Retail Policy, Nisha Arora

• FCA Expectations and Final Guidance in 2021

• The Consumer Duty Vulnerable Customers impact

Session 2: Identifying Vulnerable Customers

• Understanding the sheer scale and prevalence of vulnerability

• How can we increase the number of customers informing us of their vulnerability?

• Dealing with vulnerable customers training covers the three broad categories of vulnerability

• Permanent vs. temporary vulnerability

• Learning to  identify red flags which may suggest vulnerability

• Characteristics of vulnerable customers and how we can identify them

• Exercise: Review 18 potential causes of vulnerability and evaluate which are most likely to be recognised by front-line staff in your organisation

• Case studies: Three scenarios (elderly, illness, divorce) to identify the drivers of vulnerability for participants to work through and discuss

Session 3: Understanding the Needs of Vulnerable Customers

• Financial difficulty and vulnerability in a cost-of-living crisis

• Cause and effect - symptoms or root cause?

• Are there universal needs of vulnerable clients?

• Distribution channels which help or hinder – an understanding of the issues against typical historic approaches used by firms is covered in vulnerable customer training

• Training staff to put ourselves in the customer’s shoes without making assumptions

• How do we gather and record information relating to vulnerability – are systems fit for purpose?

Session 4: Staff Skills & Knowledge

• FCA expectations of staff

• ITDA – Interaction, Task, Detriment, Action

• 5 Key strategies to help front-line staff be the best they can be

• How do you best support your staff around vulnerability? Is eLearning sufficient?

• How to be practical when dealing with vulnerability: the BRUCE, IDEA and TEXAS models

• Topics covered in dealing with vulnerable customers training: Empathy and sensitivity

• Active listening

• The Behaviour Cycle: recognising the steps and breaking it

• How to recognise potential signs of vulnerability

• Responding: How to build confidence

• What options do they have for helping the customer?

Exercise: Understanding what stops us from having these discussions with clients and how we overcome them

Session 5: Practical Actions to Help Vulnerable Customers

• This session assesses areas where firms have historically fallen short, investigating how regulators view these issues

• Understanding what good practice looks like in your firm for your vulnerable clients

• Forbearance and its practical application

• Understanding the Vulnerability Task Force (VTF) initiative

• Sources of information and roles: Dementia Friends

• Friends Against Scams

• Money Advice Trust and WiserAdviser

• SOLLA

Exercise: Looking at the 9 VTF principles to understand their thinking, and assessing good practice ideas for Financial Services and other industries

Session 6: Governance & Reasonable Steps

• Starting session 6 of training staff to deal with vulnerable customers is alignment with the Consumer Duty work

• Evaluating policies, procedures, and processes

• Systems support – is this designed to support or made to fit?

• Organising the support functions and resources effectively

• Being clear on what can be done and empowering staff

• An enterprise-wide approach – clarity, practicality, transparency

• Management Information: How might senior managers measure the outcomes of their vulnerablility-related polices, procedures, and support measures?

• Understanding your vulnerability landscape via complaints

• Integrating your commitment to vulnerability and your financial promotions processes, product oversight, and governance

Conclusion & Course Wrap-Up

• Summary

• Questions

• Open forum

Training Objectives

Vulnerable customer training courses provide practical guidance on identifying, understanding, and supporting customers in vulnerable circumstances while meeting FCA expectations.

Sessions explore how organisations can embed effective policies, staff training, and customer-focused practices to ensure fair outcomes and cover the following:

• Practical measures to give participants the confidence in recognising and dealing with vulnerabilities.

• The FCA’s expectations on how firms should identify, support, and serve vulnerable customers.

• Guidance on how to interpret and implement requirements across your organisation.

• Recognising good practices and avoiding poor practices when training staff.

• Participants will recognise the connection between product and service design, marketing, and the experience of vulnerable customers, ensuring a cohesive, aligned approach.

• Vulnerable customer training (FCA) covers some of the discussion models available and other sources of industry best practice.

• Training reviews existing procedures and determines if they are fit for purpose and deliver the right outcomes.

• Sessions identify the regulatory developments of vulnerability from 2015 onwards, to better contextualise actions required today.

• Training looks at the role of the Vulnerability Task Force and how its work supports firms.

Training Course Summary

Training staff to deal with vulnerable customers is vital in helping firms meet the growing expectations around fair treatment and support for those in vulnerable circumstances.

While vulnerability is something most hope to avoid, there is a universal expectation of appropriate care when it does arise. Firms are recognising the importance of aligning their approach with FCA guidelines—an evolution supported by regulators and regarded as both necessary and responsible.

As a critical need for firms, training helps equip employees with the skills and knowledge to recognise, understand, and respond appropriately to vulnerability.

Companies must structure their operations with a strong focus on fairness and prioritising the needs of vulnerable customers. Senior managers, in particular, should review their practices to understand potential risks and take the appropriate steps to mitigate risks where possible.

Comprehensive sessions at Redcliffe Training provide a thorough understanding of vulnerability, how to address it, and the steps required to integrate approaches into a practical and sustainable operating model. With a clear focus on education and engagement, well-rounded vulnerable customer training encourages active participation throughout. Practical examples reinforce key concepts, ensuring the learning is not only theoretical but also applicable to real-world scenarios.