What happened?
In a recent TCC webinar, our in-house experts – Garry Evans, Chief Product and Commercial Officer, Gary Maude, Director of Advisory Practice, and Juana Diaz-Landinez, Senior Regulatory Consultant – shared practical insights on what the FCA’s expectations around vulnerability mean for firms in real terms.
In part one, Garry and Gary discuss the TCC house view about how firms should approach the identification and treatment of vulnerable customers in line with the FCA’s expectations. While the regulator’s guidance on vulnerability remains unchanged, recent supervisory activity reveals inconsistent application across the industry, prompting renewed focus from the FCA on how firms embed these requirements in practice.
Why does it matter?
The session explores key areas of concern, shares insights from recent FCA reviews and highlights where firms are falling short, not due to a lack of rules, but due to inconsistent execution and the absence of a clear strategy. With regulatory scrutiny intensifying and enforcement actions on the rise, watch or read the video transcript below to learn what actionable advice firms can utilise to strengthen governance, embed vulnerability strategies throughout the customer journey and ultimately deliver better outcomes.
Who is affected?
All regulated financial sectors, including wealth management, pensions, banking, lending, consumer credit, general insurance, and motor finance.
Recommendations
Firms should watch the full webinar series and evaluate how effectively their corporate culture translates into positive customer outcomes.
Frequently asked questions
Why are vulnerable customers receiving worse outcomes?
Mainly due to inconsistent execution, rigid processes, and a lack of proactive strategy rather than a lack of clear rules.
What percentage of vulnerable customers disclose their needs?
Only about 40% of vulnerable customers disclose their circumstances to their financial service providers.
How much can non-compliance cost a firm?
Beyond multi-million pound fines, firms face massive indirect costs from mandatory Section 166 reviews and past business reviews.
- Wealth DFM: When should firms use on-demand financial crime expertise?Analysis & Perspectives · October 14, 2026
- Motor finance redress moves towards its next legal milestoneRegulatory Horizon · October 14, 2026
- What does growing investor trust in AI mean for wealth management?Analysis & Perspectives · October 6, 2026
- Can the FCA Handbook API make compliance simpler?Analysis & Perspectives · October 2, 2026
- 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.
- Motor FinanceTCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny.
Reviewed by TCC Group Editorial Team