Guidance for firms on the fair treatment of vulnerable customers
The LITRG has responded to the Financial Conduct Authority’s (FCA) proposed guidance for firms on the fair treatment of vulnerable customers and points out the guidance should be clear that lack of knowledge or capability when it comes to dealing with tax and welfare benefits is a key driver of vulnerability. We recommend that specific mention of tax and welfare benefits be included in the guidance so that these matters are fully incorporated into regulated firms’ way of thinking.
We fear that if this is not incorporated, and firms are not pressed to stop and think about these issues, the result will be poor customer outcomes. Potentially vulnerable customers will continue to become actually vulnerable as a result of financial decisions creating an unexpected tax liability, benefits overpayment or compliance problem (such as a penalty).
Our submission can be found here: Guidance for firms on the fair treatment of vulnerable customers – LITRG response