Vulnerable Customers

FCA Expectations Explained & How to Take Action

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One-day vulnerable customer training

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Download: Course Outline

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

Session 4: Staff Skills & Knowledge

Vulnerable Customer Training: 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 for inclusion:
- 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

This session of vulnerable customer training begins by looking at 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 concludes dealing with vulnerable customers training

Conclusion & Course Wrap-Up

Summary
Questions
Open forum

At Redcliffe, vulnerable customer training courses are led by a specialist with over 20 years of experience in financial services and compliance and an already 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 customer training expert has also 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
Vulnerable customer care

The trainer leverages this experience to further enrich engaging and insightful training.

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.
Vulnerable customer 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.

Dealing with vulnerable customers training reflects the latest FCA expectations, best practices, and mandatory updates. Sessions remain current, relevant, and aligned with regulatory developments.
Redcliffe has extensive experience delivering training across the financial sector. We have a deep understanding of regulated firms’ obligations and regulatory expectations.
Redcliffe Training has over 20 years of experience delivering high-quality training, with standards matching the best in the industry.
Delivered by an industry expert with first-hand regulatory and training experience, providing practical insights tailored to both wholesale and retail financial firms
Our seasoned expert has regulatory and training experience across wholesale and retail financial firms. Sessions offer practical insights, enhancing the course's relevance and impact.
We do not use academics. All our experts have relevant vocational experience in real-world settings.
Training staff to deal with vulnerable customers utilises case studies to enhance learning. Participants find these essential in understanding requirements and growing the skills to apply them.

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 vulnerable customer training at Redcliffe provides 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.

The instructor was excellent.
The trainer was clearly very knowledgeable in this subject. He was very engaging throughout the session. He provided some great slides; however, these were only used as a guide, as the training was very much direct and thorough, rather than most training sessions, where they just read from the slides.
This was a good refresher covering VC and understanding how it changes continuously due to climate changes, such as COVID and the Cost of Living. Very good, very enjoyable.
I am a Quality Assurance Analyst, and I am an SME (Subject Matter Expert) in Vulnerable Customers. This was hugely informative from a regulatory perspective as the trainer could explain what the FCA is looking for and where it is heading. This helped me think about how my team is already implementing these needs and what gaps we have. We, as a group, got to ask a lot of questions from high-level to specifics within our jobs - the trainer was friendly, engaging, and very knowledgeable.
The course reinforced the basic knowledge I had with regard to Vulnerable Customers; however, the content of this course made me aware of improvements that could be made, along with consistency across the group and made me aware of the regulatory position with regard to VC.
It was brilliant - very informative.
The course was very informative and enlightening. It got to me think a lot more outside the box and considering alternative options.
It was very helpful for me as I am tasked with updating our vulnerable customer eLearning and writing SOP for our new Customer Service VC Team. I really liked the way the trainer worded some examples. Great ideas and kept things simple.
As a new member of BHSF's Vulnerable Customer Team, I have gained an enhancement of skills I will be bringing to the team and to consider when speaking to vulnerable customers.
Really good course, very helpful, and took a lot away.