Banks and Vulnerable Customers

The Financial Conduct Authority (FCA) recently conducted a multi-firm review examining how retail banks and building societies manage customers in vulnerable circumstances, particularly those dealing with bereavement and Power of Attorney (PoA). This review forms part of the FCA’s Consumer Duty, which requires firms to deliver positive outcomes for all customers, including those facing vulnerable situations. The review assessed customer outcomes, governance structures, staff training, management information (MI), and outcome testing within financial institutions.The findings are particularly relevant to retail banks, building societies, and possibly some payment and electronic money institutions. Along with the new insights, the FCA also drew on lessons from its previous review of life insurers’ bereavement claims processes, encouraging banks to apply these best practices to their own operations. The central message is that the measurement, monitoring, and delivery of good customer outcomes are vital to ensuring the fair treatment of vulnerable customers.Key FCA guidance referenced in the review includes the Consumer Duty (Principle 12 and PRIN 2A), which mandates that firms act in the best interests of vulnerable customers throughout their entire customer journey. The FCA also highlights the Vulnerability Guidance (FG21/1), which outlines expectations for the fair treatment of vulnerable customers. Additionally, PRIN 2A.6.5R and PRIN 2A.7.4G specifically require firms to provide equal support to those authorised to act on behalf of retail customers, such as individuals holding a PoA, and to ensure systems are in place to identify and respond to customer needs.Several positive practices were identified during the review, including the development of clear policies and procedures for vulnerable customers, which include specific guidelines for processing bereavement and PoA cases. Some firms had implemented systems that enabled staff to easily access customer needs, ensuring a more consistent and empathetic experience. Other firms proactively identified customers at risk of vulnerability using data analytics, such as transaction patterns, to better tailor their responses.Staff training was also highlighted as a critical area. The review found that many firms used artificial intelligence (AI), such as speech analytics, to identify potential signs of vulnerability in real time. This allowed staff to adjust their approach and provide appropriate support during customer interactions. Outcome monitoring was another strong point, with firms tracking metrics such as time to register PoAs, account closures in bereavement cases, complaints, and customer satisfaction scores. This data-driven approach is key to measuring whether vulnerable customers are receiving adequate support.However, the review also identified areas requiring improvement. Some firms struggled with unclear guidance during emergencies, such as when a customer’s capacity changed unexpectedly. This lack of clarity sometimes led to delays or unnecessary distress for customers. The FCA recommends that firms ensure their policies are accessible, clearly define escalation processes, and maintain flexible solutions to handle complex cases.The FCA’s findings indicate that firms must focus on enhancing their systems, staff training, and customer journey management to meet the regulatory expectations of the Consumer Duty. Firms should take these insights seriously and implement changes that ensure the fair treatment of vulnerable customers.