In the final part of our vulnerable customers webinar series, Garry Evans, TCC’s Chief Product and Commercial Officer outlines TCC’s house view which aligns with the FCA’s five key areas of focus.

Watch as Garry summarises the importance of aligning culture and strategy, designing adaptable services with vulnerability in mind and ensuring that processes, data and oversight mechanisms are in place to deliver and evidence good customer outcomes.

Watch the final part here or read the transcript below:

Garry Evans:

I’m conscious that we’ve had an awful lot of information, passed over to you over the last 26 minutes. So, what I’m going to try and do is try and summarise that into what the TCC house view is. Looking at the five key areas that the FCA cares about, starting with a line, as kind of Gary mentioned here, the culture and the strategy need to be clearly aligned, and they need to be evidencable as well. From an adapt perspective, you need to ensure that your products have been designed with vulnerability in mind.

You need to review your products and your services regularly to ensure that they are vulnerable customer ready. If you recognise that vulnerable characteristics can be multiple, they can also be transient and that your treatment plan may need to change, so make sure that’s adaptable. For identifying vulnerability, you need to ensure that your processes and systems direct the right questions to be asked, and that your environment is safe and comfortable for customers to be transparent.

You also need to ensure that the right data is captured to enable the decision of future customer treatment and before treating vulnerable customers appropriately, and to ensure you’re driving consistency in your approach at the same time as empowering your staff to work with vulnerable customers in their circumstances. You need to use your data – the data you capture – to determine what additional support or differentiated treatment is required, if any, and then make sure you execute that differentiated treatment.

And lastly, around evidence and good outcomes. If you have a treatment plan, you need to be able to evidence that you have actually applied that treatment plan. You need to be aware and reproduce your plans and deliver ongoing oversight right away through to completion.

You need to create an MI portfolio approach to understand how well you’ve done – listen to and assess that the statistically significant number of life cycle journeys with your vulnerable customers. Generate input from customers on your services before you actually build them, and ensure your understanding how satisfied your customers are at the planning stage.

Once you have all this MI, you need to ensure that that MI is reviewed regularly by the right decision makers with action plans agreed and followed up on to deal with any areas of concern. And you need to have demonstrable links to the key controls and committees to ensure that this is held at a high level.

Ready to watch the rest of the webinar? You can watch the full 30 minutes below.

Now is the time to evaluate how effectively your firm identifies and supports vulnerable customers. Take a fresh look at your strategy, systems and data to ensure they align with regulatory expectations and deliver meaningful outcomes.

TCC’s experts can help by assessing your current approach, identifying gaps and putting actionable plans in place to evidence real progress. Get in touch today to discuss your next steps.