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