UK FCA findings from review of how payments firms support vulnerable consumers

The UK Financial Conduct Authority (FCA) has published findings from its review of how payments and e-money firms are supporting consumers in vulnerable circumstances under the consumer duty. The review assessed firms' approaches to identifying vulnerability, providing tailored support and monitoring customer outcomes. The FCA found many examples of positive practice but also identified specific areas for improvement, including:

• Some firms identified very few or no customers in vulnerable circumstances, despite having customer bases where characteristics of vulnerability may reasonably be expected.
• There was limited testing or assurance to assess how effectively identification policies were being implemented in practice.
• Approaches on support arrangements were not always applied consistently across the customer journey, and some firms could not clearly evidence how vulnerability information translated into tailored support for customers.
• Communications relied primarily on standard formats, with limited tailoring for customers with different needs, and limited assessment on whether communications were understood and effective in practice.
• The frequency and quality of management information provided to senior management and boards could be improved. Boards at certain firms received limited insight beyond annual consumer duty reporting, and vulnerability data and outcomes information were not consistently recorded, reducing firms' ability to identify trends and take corrective action.
• Understanding the impact of distribution arrangements on consumer outcomes.

Firms are advised to consider these findings when assessing their own arrangements. The FCA will continue to engage with firms in this area and intervene where necessary.

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