All firms should treat all customers fairly, regardless of gender, race, sexuality, and any other characteristics. Vulnerable clients should be paid special attention to make sure their needs are understood.
The FCA provides a set of rules with respect to vulnerable clients along with guidance on how those rules should be applied. All firms are expected to follow the rules, and the FCA, PRA and ombudsman will consider the rules and the guidance when making any investigations.
The FCA requires firms to:
- Understand the needs of vulnerable clients.
- Ensure staff have the necessary skills and capabilities.
- Take appropriate and practical action.
Communication, product design, and operations should all embed the rules around fair treatment of vulnerable clients. The FCA has begun applying a ‘vulnerability law’ to all of its oversight activities.
Where practicable, it is helpful for the vulnerable client to have someone with them when they attend meetings. However, this is not necessary. The advisor should always make sure policies and pledges are laid out clearly and are accessible to the vulnerable person, so that they know their rights and what they can expect from the advisor and demand from the advisor. Communication must be clear and jargon free and preferably also in writing where appropriate. Firms should make sure that their staff are trained and that only capable staff are allowed to work with vulnerable persons.
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