A deep dive into Consumer Duty’s cross-cutting rules
That vulnerability is not included within Consumer Duty as an explicit cross-cutting rule can create some debate as to its importance within the various rules. Andrew Gething and Tony Crane look at although this isn’t the case, vulnerability is included within each cross-cutting rule – so its importance within Consumer Duty shouldn’t be downplayed. They examine practical examples – such as the rule for acting in good faith and the rule for avoiding foreseeable harm, which include within them avoiding harm to vulnerable customers. In a sense, vulnerability cross-cuts all of the vulnerability rules – making it one of the most important aspects of Consumer Duty.
Latest white paper
Understanding the implications of vulnerability within Consumer Duty
Our latest Consumer Duty white paper
This paper examines the FCA Handbook Rules on Consumer Duty Regulations, specifically Principle 12. We extracted some key rules in order to explain the practical implications.
Latest podcast
What is a vulnerability?
Our latest Consumer Duty podcast
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.
Latest webinar
Managing vulnerability in consumer credit
Our latest Consumer Duty webinar
The FCA has announced that it is reviewing how vulnerability is being managed. What are the practical implications for consumer credit, particularly in the motor finance sector, where credit is so important? We look at: what does consumer vulnerability look like, and what is required under Consumer Duty in consumer credit? We talk about the elephant in the room – the sale – the conflict of assessing consumers and minimising friction in the sale. And we ask what are the costs, benefits and risks of assessing consumer vulnerability? We also look at: personalisation of communications, comparisons of buying journeys, what the motor finance sector ‘doesn’t know’ about other areas of financial services – and we talk about the FCA’s current thinking and offer insights into what’s coming down the line from the regulator.