What happened?
In the second part of TCC’s vulnerability webinar series, Gary Maude and Garry Evans focus on how firms can align strategy, culture, and operational controls to deliver positive outcomes.
A successful approach requires senior management to actively drive a clear risk appetite down through the business, rather than allowing individual business areas to create their own siloed cultures.
Why does it matter?
Firms often struggle with the ’empowerment conundrum’—allowing frontline staff flexibility to help vulnerable clients while maintaining regulatory consistency.
Without structured parameters and detailed process granularity, decisions become highly subjective, leading to inconsistent treatment and the dilution of strategic controls.
Who is affected?
Operational leaders and compliance teams across banking, consumer credit, wealth management, insurance, and motor finance.
Recommendations
Firms should review their operational processes to ensure they provide sufficient granularity for staff to handle multiple and transient vulnerabilities consistently.
Frequently asked questions
How does culture impact a vulnerability strategy?
Culture must be driven down from senior management to ensure all business units adhere to a unified risk appetite and compliance standard.
What is the empowerment conundrum?
It is the challenge of giving staff flexibility to support vulnerable clients while maintaining consistency to avoid subjective decision-making.
What is the difference between 'fair' and 'nice'?
For example, allowing a client to make minimum payments to be ‘nice’ might keep them in debt longer and harm their credit rating, which is not ‘fair’.
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Reviewed by TCC Group Editorial Team