Vulnerable Customers

Session 1: Introduction – The Regulatory Position

Vulnerable customers training introduces the key regulatory standards and best practices for effectively identifying, engaging with, and supporting vulnerable customers. This session covers:

• Occasional Paper 8
• The FCA definition of a vulnerable customer
• GC19/3 and GC20/3: Guidance for firms on the fair treatment of vulnerable customers
• Assessing the March 2020 TISA Vulnerability Conference speech by the FCA’s Director of Consumer and Retail Policy, Nisha Arora
• FCA Expectations and Final Guidance in 2021
• The Consumer Duty Vulnerable Customers impact

Session 2: Identifying Vulnerable Customers

• Understanding the sheer scale and prevalence of vulnerability
• How can we increase the number of customers informing us of their vulnerability?
• Dealing with vulnerable customers training covers the three broad categories of vulnerability
• Permanent vs. temporary vulnerability
• Learning to identify red flags which may suggest vulnerability
• Characteristics of vulnerable customers – how we can identify them
• Exercise: Review 18 potential causes of vulnerability and evaluate which are most likely to be recognised by front-line staff in your organisation
• Case studies: Three scenarios (elderly, illness, divorce) to identify the drivers of vulnerability for participants to work through and discuss 

Session 3: Understanding the Needs of Vulnerable Customers

• Financial difficulty and vulnerable customers (in a cost-of-living crisis)
• Cause and effect? Symptoms or root cause?
• Are there universal needs of vulnerable clients?
• Distribution channels which help or hinder – an understanding of the issues against typical historic approaches used by firms
• Training staff to deal with vulnerable customers includes putting ourselves in the customer’s shoes without assuming
• How do we gather and record vulnerability information – are systems fit for purpose?

Wrap-up, summary and delegate Q&A

Session 4: Staff Skills & Knowledge

• FCA expectations of staff
• ITDA – Interaction, Task, Detriment, Action
• 5 Key strategies to help front-line staff be the best they can be
• How do you best support your staff around vulnerability? Is eLearning sufficient?
• How to be practical when dealing with vulnerability: the BRUCE, IDEA and TEXAS models for vulnerable customers
• Topics covered during this vulnerable customer training:
  • Empathy and sensitivity
  • Active listening
  • The Behaviour Cycle: recognising the steps and how to break it
  • How to recognise potentially vulnerable customers
  • Responding: How to build confidence
  • What options do they have for helping the customer?
• Exercise: Understanding what stops us from having these discussions with clients and how we overcome them

Session 5: Practical Actions to Help Vulnerable Customers

• What the industry is judged to do incorrectly
• Understanding what good practice looks like in your firm, for your vulnerable clients
• Forbearance
• Understanding the Vulnerability Task Force (VTF) initiative
• Sources of info and roles:
  • Dementia Friends
  • Friends Against Scams
  • Money Advice Trust and WiserAdviser
  • SOLLA
• Exercise: Looking at the 9 VTF principles to understand their thinking, and assessing good practice ideas for Financial Services and other industries

Session 6: Governance & Reasonable Steps

• Alignment with the Consumer Duty work
• Evaluating policies, procedures, and processes
• Systems support – designed to support or made to fit?
• Organising the support functions and resources effectively
• Being clear on what can be done and empowering staff
• An enterprise-wide approach – clarity, practicality, transparency
• Management Information: How might senior managers measure the outcomes of their vulnerable customer measures?
• Effective processes for recording and addressing vulnerability – a one-stop shop
• Understanding your vulnerability landscape via complaints
• Integrating your commitment to vulnerability and your financial promotions processes, product oversight, and governance

Conclusion & Course Wrap-Up

• Summary
• Questions
• Open forum

Vulnerable customer training courses at Redcliffe are led by a specialist with over 20 years of experience in Financial Services and Compliance, and a successful background in training staff on subject matter.

Redcliffe's seasoned educator and finance expert has a proven track record in compliance topics, financial crime and regulatory issues. Serving as Head of Education for HSBC across the UK and Europe, our expert delivered compliance programs focused on regulatory requirements and financial crime prevention. His tenure coincided with a period of intensified regulatory oversight, including the bank’s Deferred Prosecution Agreement, during which he played a pivotal role in ensuring adherence to enhanced compliance standards.

Our vulnerable customers training expert has held senior positions in compliance and risk management. He led the Monitoring and Testing program for a UK Wealth Manager and served as Senior Vice President for Global Risk & Compliance Training at a US-based bank. He also worked at the Financial Conduct Authority (FCA), where he was the expert on rules within the Training & Competence Handbook for the Insurance Firms Division.

His extensive experience across financial services and regulatory bodies gives this trainer a unique perspective on: compliance, risk management, and vulnerable customer care.

The trainer leverages his experience to further enrich engaging and insightful sessions.

Vulnerable customer training courses at Redcliffe include:

• Practical measures to help your firm deal with vulnerable customers with confidence.
• The FCA’s expectations on how firms should identify, support, and serve vulnerable customers.
• Guidance on how to interpret and put these requirements in place across the organisation.
• Recognising good practices and avoiding poor practices when training staff.
• Recognise the connection between product and service design, marketing, and the experience of vulnerable customers, ensuring a cohesive and aligned approach.
• Skilling staff to recognise vulnerability.
• To highlight some of the discussion models available and other sources of industry best practice.
• Review your vulnerable customer procedures and determine if they are fit for purpose and deliver the right outcomes.
• Dealing with vulnerable customers training identifies the regulatory developments of vulnerability from 2015 onwards, to better contextualise actions required today.
• The role of the Vulnerability Task Force. We cover how their work supports firms.

Vulnerable customer training courses are for professionals working in regulated firms. While much of the session references FCA rules, the underlying principles promote effective and consistent service for customers regardless of jurisdiction. Ideal for:

• First-line staff who engage directly with clients, manage teams with customer-facing roles, oversee the firm’s approach to vulnerability, or contribute to the design of training frameworks, offering practical insight and guidance at every level.
• Second and third-line staff who are advising risk owners or evaluating systems and controls in place to meet vulnerability requirements will also find training valuable.

Training staff to deal with vulnerable customers plays a vital role in helping firms meet the growing expectations around fair treatment and support for those in vulnerable circumstances.

While vulnerability is something most hope to avoid, there is a universal expectation of appropriate care when it does arise. Firms are recognising the importance of aligning their approach with FCA guidelines—an evolution supported by regulators and regarded as both necessary and responsible. As a critical need for firms, training helps equip employees with the skills and knowledge to recognise, understand, and respond appropriately to vulnerability.

Companies must structure their operations with a strong focus on fairness and prioritising the needs of vulnerable customers. Senior managers, in particular, should review their practices to understand potential risks for vulnerable clients and take the appropriate steps to mitigate risks where possible.

Comprehensive sessions at Redcliffe Training provide a thorough understanding of vulnerability, how to address it, and the steps required to integrate approaches into a practical and sustainable operating model. With a clear focus on education and engagement, well-rounded sessions encourage active participation throughout. Practical examples reinforce key concepts, ensuring the learning is not only theoretical but also applicable to real-world scenarios.