What happened?
The Consumer Duty raises the standard for customer protection across financial services, placing greater emphasis than before on firms’ need to identify and manage vulnerability among their customers on an ongoing basis.
Writing in Money Marketing, TCC Group’s Chief Product Officer Garry Evans examines how this higher standard requires firms to take a more proactive approach to vulnerability, and offers guidance on building a safeguarding strategy that can adapt over time.
Why does it matter?
Firms that treat vulnerability as a one-off assessment, rather than an ongoing part of customer management, are unlikely to meet the standard the Consumer Duty sets, and may struggle to evidence that vulnerable customers are receiving good outcomes.
Supporting sources
Frequently asked questions
What does the Consumer Duty require regarding vulnerability?
It requires firms to identify and manage customer vulnerability on an ongoing basis, not as a one-off assessment.
Who wrote this analysis?
TCC Group’s Chief Product Officer, Garry Evans, writing in Money Marketing.
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- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- General Insurance & ProtectionTCC helps insurers, brokers, MGAs and protection providers evidence fair value, strengthen customer outcomes and identify emerging customer harm. We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle.
- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Wealth Management & Financial AdviceTCC helps wealth managers, financial advisers, networks, platforms and consolidators strengthen compliance, evidence customer outcomes and manage regulatory risk. Every engagement is designed to deliver practical improvements, stronger governance and regulator-ready evidence. For more than 25 years, we have helped FCA-regulated firms navigate regulatory change, supervisory reviews and business growth.
