Consumer Duty podcasts

Some of our latest thoughts and insights on a range of Consumer Duty and customer vulnerability topics, ideal for listening on the go.

What is a vulnerability?

A Consumer Duty podcast (05:01)

There is still a great deal of uncertainty about how someone is defined as vulnerable; what a vulnerability is. The FCA’s data (confirmed with live data from MorganAsh’s vulnerable consumer management tool, MARS) shows that around half of all people can be defined as vulnerable. Yet others say that they have only a few per cent of vulnerable consumers. Can this be true? Andrew Gething and Johnny Timpson OBE try to dig into the answers.

Reporting under the Equality Act

A Consumer Duty podcast (02:45)

While people prepare to report under Consumer Duty, Andrew Gething observes that one of the things many companies don’t understand is that Consumer Duty also requires them to report under the Equality Act. The Act has been around for some years, but many haven’t recognised the part it plays in Consumer Duty. Johnny Timpson OBE shares his thoughts.

Will the FCA be lenient or harsh?

A Consumer Duty podcast (4:04)

As we head towards the FCA’s first review, we’re in uncharted territory. No one really knows what the stance of the regulator will be – they can only guess. Any form of action is, of course, likely to be proportionate to the failure to meet Consumer Duty. The problem is that one person’s view of a ‘bad outcome’ may be different from another’s – so what will be the regulator’s view?

Sharing vulnerability data

A Consumer Duty podcast (6:08)

When assessing the vulnerability of consumers, most firms store that data themselves and don’t share it. The problem with this is that it means consumers may well be answering the same types of questions again and again – tiresome, to say the least. And, if different firms assess people in different ways, the results of those assessments and how they are subsequently treated will also differ. Some sectors, such as utilities, are starting to get around these issues by sharing data. But what are the challenges, advantages and pitfalls of this? Andrew Gething and Johnny Timpson OBE discuss.

Consumer Duty: vulnerability or suitability?

A Consumer Duty podcast (3:23)

Consumer Duty uses the term ‘vulnerability’ – but is that word itself unhelpful? Does it come with preconceptions, stigma or assumptions? Is the term ‘suitability’ more appropriate? Andrew Gething and Tony Crane discuss the need for labels – but also why the need to have a common understanding of these is important.

Can you meet Consumer Duty without monitoring individual customers?

A Consumer Duty podcast (15:32)

What happens if you decide to not monitor individual customers – and just assume that half of them are vulnerable but you believe they all have good outcomes? How far down the path of risk does that go? If some monitoring takes place at the point of claim, or when an issue is raised, is that enough? Under Consumer Duty a firm is required to demonstrate that it is treating people with vulnerability characteristics as fairly as those without – so being passive, argues Andrew Gething when discussing this with Tony Crane, isn’t enough. 

Managing and avoiding harmful outcomes

A Consumer Duty podcast (09:15)

While all firms will have activities in place to avoid harms, it’s certain that these aren’t as robust as Consumer Duty would expect. Andrew Gething shares his experience of assessing vulnerable consumers, what can be done when a vulnerability is discovered – and why many current next steps are unlikely to help actually address that vulnerability. Also, vulnerabilities are often looked at in isolation, but real issues arise when people experience more than one vulnerability – and addressing these holistically, rather than separately, happens far too infrequently.

Whose job is it to monitor a consumer’s vulnerability?

A Consumer Duty podcast (10:21)

Under Consumer Duty, there is an obligation to monitor the customer throughout the lifetime of the product. For some products (say, mortgages) that monitoring should take place over many years. Who has to do the monitoring? Is it the adviser, manufacturer – or both of them? Someone has to do it – Andrew Gething and Tony Crane look at how this can be based on circumstance, relationship, product creation and more. All parties need to understand who is doing it and not assume that it’s being done by someone else; there is always an obligation to know that this is done.

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