FCA findings on multi-firm review of customers in vulnerable circumstances

A&O Shearman
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A&O Shearman

The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings of its multi-firm review on retail banks' treatment of customers in vulnerable circumstances involving bereavement and power of attorney (PoA). The webpage is accompanied by a press release. The Consumer Duty requires firms to deliver good outcomes for all customers, including those in vulnerable circumstances. The multi-firm review makes a series of findings, including on:

  • policies and procedures: the FCA calls for firms to make guidance for staff accessible and policies to be clear that staff should adapt to customers' needs and recognise when matters should be escalated.
  • identifying and responding to customer needs: the FCA encourages firms to identify signs of vulnerability and seek information from consumers to address their needs. The FCA also wants firms to establish feedback loops to enable continuous improvement of staff and processes based on previous errors.
  • outcomes testing and monitoring: there is scope for improvement, particularly in management information reporting, as firms' data was found to lack breadth and detail. There was also a lack of clarity on what firms consider to be good or bad outcomes.
  • customer journeys: firms have limited channels for attorneys to access a relevant customer's account, with online banking often unavailable for them to use. Fragmented customer relationship systems across business lines could make it difficult to progress cases efficiently. The FCA encourages firms to efficiently streamline communication systems across teams to prevent customers (particularly in bereavement and PoA processes) from repeating information, or having their cases delayed or dropped altogether.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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