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.
