Following the release of the FCA’s pure protection market study, in which the regulator highlights the barriers vulnerable customers can face when accessing appropriate protection, we have a comment from support services provider and Consumer Duty specialists MorganAsh.
New research highlighting the widespread impact of financial stress should prompt financial services firms to examine whether they do enough to proactively identify customers who may be struggling, according to MorganAsh.
This webinar looks at how better customer understanding and personalisation can unlock considerable benefits, the sector-by-sector case for digital assessment, and how loyalty and early engagement can be the difference between a manageable case and a write-off. The session includes a live case study that shows the commercial benefits playing out in practice: fewer auto-declines, more approvals, and a new product launched off the back of better insights.
Many firms question whether they can record and share data about vulnerable customers without falling foul of GDPR. The joint FCA/ICO statement of March 2026 made clear that data protection law is not a barrier but an enabler. Drawing on the CII's recent practical guide to GDPR and data privacy, three of the guide’s co-authors – Andrew Gething of MorganAsh, Robert Bell, and Vanessa Riboloni of the CII – move the conversation from “are we allowed?” to “how can we do this well?”.
Customer vulnerability specialists from MorganAsh also speak regularly at industry events. View speaking events
Typically, affordability and customer vulnerability have sat in different parts of the business. Credit risk looks after affordability: can this person repay what they’re borrowing? Compliance and customer experience are responsible for customer vulnerability: does something about this person’s circumstances mean they need extra support? Different teams, different systems, different reports to the board.
For financial services firms, complaints have long stood as both an important measure of customer experience – and a necessary part of regulatory reporting. From January 2027, however, they will serve a third purpose – providing the regulator with greater insight into how firms both identify and support customers in vulnerable circumstances.
According to the FCA’s Financial Lives survey, around half of all people are vulnerable at any one time. This seems like a lot – is it accurate? And, if it is so many, what can firms do about it? Many firms are only very identifying low numbers of vulnerable customers – what are they missing?
Elephants Don’t Forget, FWD Consulting, MorganAsh, and the Collaboration Network answer your questions about implementing the FCA’s Consumer Duty requirements on customer vulnerability within your firm.
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.
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.
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