Can you meet Consumer Duty without monitoring individual customers?
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.
