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Building societies will have a head start – it’s always been key to the success of a building society to make sure customers are being listened to and are receiving a personalised service. Industry commentators have suggested that the Consumer Duty will have less of an impact on organisations who are already focussed on these areas, but it may still require a greater focus, a period of upskilling and retraining and changes to policies and procedures. With a regulatory obligation to ensure customers make good decisions based on their needs and characteristics, a thorough understanding of the different vulnerability factors will be crucial at every point of customer contact.  I am sure all staff already "avoid causing foreseeable harm", but the proposed "cross-cutting rules" will require organisations to prove they are taking "all reasonable steps" towards these outcomes.

 

To meet these requirements, organisations are going to need to look at how they're documenting vulnerable customers, what MI is being generated, and what's being done with that data. I think there is a danger of businesses appointing vulnerability champions or a specialist team and treating that as the solution. This change in the FCA approach requires a re-examination of strategy - can all four of those crucial outcomes be provided to every vulnerable customer? Are vulnerable customers consistently receiving the level of service the FCA is looking for - and how can you prove it?

 

What will that change look like for your society? With months to go before any rules come into effect, it’s important to begin thinking about vulnerability at every stage of the customer journey. I am confident building societies will lead the way in setting standards of Consumer Duty – as they always have.