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Vulnerable Customers

2 Part Course  |  Learn about the FCA expectations and understand how to respond

Vulnerable Customer Workshop

A one-day course presented in two half-day live webinars from 9:30am to 1:00pm UK time

Video Overview

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  • The vulnerable customer training session is designed for those working in regulated firms and while much of the session references FCA rules, the underlying principles support effective customer support regardless of jurisdiction. First line staff will gain value when they are dealing with clients directly or managing teams that have client interaction, overseeing the firm’s response to vulnerability, involved in the design of training frameworks to address vulnerability responses or those who simply wish to understand more.
  • Second- and third-line staff who are advising risk owners or evaluating systems and controls in place to meet vulnerability requirements, will also find this webinar valuable in ensuring appropriate coverage of their work.

  • We are well aware of how FCA expectations have changed alongside the best practice and mandatory updates.
  • We have served clients of all shapes and sizes in the financial sector and are fully aware of the obligations of a regulated firm and what is expected from them by the regulator.
  • We have been delivering training for over 20 years. We are certain we know the topic as well as anyone in the market place
  • The Vulnerable Customers course director is experienced as both a regulator and in training regulatory requirements across wholesale and retail financial firms. He will pass on past experiences to enhance the workshop and help bring it to life
  • We do not use academics. All our trainers are highly experienced professionals with relevant vocational experience in the real world
  • Our case studies enhance the learning points and are often found to be essential in truly understanding the requirements and growing the skills to apply them
  • We are always judged by our results which speak for themselves and the feedback received from previous delegates has always been excellent.

  • To be able to take forward practical measures to help your firm deal with vulnerable customers confidently and effectively.
  • To understand the FCA’s expectations on how firms are expected to serve vulnerable customers and organise themselves to do this consistently.
  • To recognise good practice / avoid poor practices
  • To recognise the linkages between the design and marketing of our products / services and our vulnerable customer experience – in other words, joined-up thinking
  • Understanding how we skill our staff to recognise vulnerability
  • To highlight some of the discussion models available and other sources of industry best practice
  • To be able to review your vulnerable customer procedures determining if they are fit for purpose and deliver the right outcomes
  • Be able to identify the regulatory developments around vulnerability from 2015 onwards to better contextualise actions required today.
  • Understand the role of the Vulnerability Task Force and how they help us.

Part 1

Session 1: Introduction – the regulatory position

  • 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 Nisha Arora, Director, Consumer and Retail Policy
  • FCA expectations and Final; Guidance in 2021
  • Impact of the Consumer Duty on dealing with vulnerable customers

Session 2: Identifying Vulnerable Customers

  • Understanding the scale and prevalence of vulnerability
  • How can we increase the number of customers informing us of their vulnerability?
  • Three broad vulnerability categories
  • Permanent vs. temporary vulnerability
  • Red flags which may suggest vulnerability
  • Characteristics of vulnerable customers – how can we identify them
  • EXERCISE: review 18 potential causes of vulnerability and consider which ones would be largely recognised by front-line staff in your firm
  • CASE STUDIES: three scenarios to identify the drivers of vulnerability for participants to work through and discuss (elderly, illness, divorce)

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
  • Putting ourselves in the customer’s shoes without assuming
  • How do we gather and record vulnerability information – are systems fit for purpose?


  • Summary
  • Questions

Part 2

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
  • How do you best support your staff around vulnerability – is eLearning sufficient?
  • How to practically deal with vulnerability: the BRUCE, IDEA and TEXAS models for vulnerable customers
  • Topics for inclusion in training:
    • Empathy and sensitivity
    • Active listening
    • The Behaviour Cycle – recognising the steps and how to break it
    • How to recognise potential 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 that)

Session 5: Practical Actions to help Vulnerable Customers

  • A look at what the industry is judged to do wrongly
  • 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; assessing good practice ideas for Financial Services and other industries.

Session 6: Governance & Reasonable Steps

  • Alignment with The Consumer Duty work
  • 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 and product oversight & governance

Course Wrap-up:

  • Summary
  • Questions
  • Open forum

With over 20 years training experience in financial services, the trainer is well placed to support you across a range of compliance-related topics. He is a former Head of Education for HSBC covering the UK and Europe, responsible for regulatory and financial crime related compliance learning. His time at HSBC was during intense scrutiny from regulators and government functions during the bank’s Deferred Prosecution Agreement.

Other roles include leading the Monitoring and Testing programme for a UK Wealth Manager, and Senior Vice President responsible for Global Risk & Compliance training at a US-based bank. He also worked in the Insurance Firms division at the Financial Conduct Authority (in the FSA days) where he was the divisional expert for the rules and outcomes required under the Training & Competence handbook.

Since leaving HSBC, he has worked with the compliance, HR and operational teams of firms to enhance their regulatory understanding, as well as delivering content across private equity firms, investment houses, banks and wealth managers. Stephen regularly delivers core programmes for TISA (The Investing and Savings Alliance) and the Investment Association.

The vulnerable customer training course director is a former member of the Investment Management Association Training & Education Committee and won the Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm” in 2010. 

Vulnerability is one of those topics where we all hope to be less impacted on a personal level, but also that we would receive appropriate care and support if we were.  Increasingly, a commitment to helping vulnerable customers in line with FCA guidance is being widely accepted as the only right and proper thing to do, with the regulators, naturally supporting this shift. The sense for some time now is that firms need to be doing more. 

Firms need to ensure their staff are appropriately skilled in identifying and responding to vulnerability.  They also need to ensure they are organising their business effectively with a focus on treating all their customers fairly but none more so than those experiencing vulnerability.  Firms and especially senior managers should be looking at what they are doing to understand these potentially negative outcomes for vulnerable clients and the steps they are taking (or should be taking) to mitigate those.

The webinar helps participants to understand what vulnerability is, how it needs to be addressed and the steps they need to take to build these approaches into a practical and sustainable operating model.  It is designed to be enjoyable as well as instructional with delegate participation actively encouraged. Practical vulnerable customers examples are used to illustrate the learning points rather than leaving them as theoretical.

  • Instructor was excellent
Number of places:
Part 1
Number of places:
Part 2

£ 695.00

Per participant per part

Discounts available:

Book multiple places on both parts in one order for the below discounts:

  • 2+ places at 40% less = £ 834.00
    per person
  • 4+ places at 50% less = £ 695.00
    per person
  • 6+ places at 60% less = £ 556.00
    per person
  • 9+ places at 70% less = £ 417.00
    per person

    Have this course presented In-House

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