The Financial Conduct Authority (FCA) has launched a consultation on draft guidance to help firms better understand how to treat vulnerable customers fairly.
The guidance draws attention to Personal Contract Purchase (PCP), hire purchase and Personal Contract Hire (PCH), raising concern that if products and services are complex, vulnerable customers may find it more difficult to buy what is best suited to their needs.
The FCA’s expectation is for firms to;
- understand the nature and scale of drivers with vulnerabilities in their target market and customer base,
- ensure that all staff, particularly those at the frontline, have the right skills and capability to treat vulnerable customers fairly,
- consider the needs of vulnerable customers at all stages of product and service design,
- deliver a good customer service that takes a flexible approach to the individual needs and circumstances of vulnerable customers, providing specialist support where appropriate,
- ensure communications are clear and easy to understand throughout the lifecycle of a product or service, including marketing, point of sale, and post-contract,
- monitor understanding of vulnerable consumers across the business and monitor how staff actions affect the outcomes vulnerable customers are experiencing.
While the guidance is not binding on firms, the FCA has stated that it may use the guidance in an enforcement context.
The consultation, which also contains case studies of good practice, closes on 4 October.
Please contact BVRLA’s Senior Policy Advisor Jinmi Macaulay with your views by 6 September.
