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The fair treatment of vulnerable clients; a priority for the FCA and for Level

If 2020 taught us anything, it’s that anyone can be vulnerable. The FCA’s key area of focus for 2020/2021 is ‘ensuring that the most vulnerable are protected' and with that in mind last week they published updated draft guidance to help firms treat vulnerable clients fairly. Here at Level, we welcome both the focus on vulnerable clients and this updated guidance. We provide funding to people who are going through divorce and contested probate proceedings. That can be tough at any time, but with the global pandemic and a potential recession on top, we and the law firms that we work so closely with, have to pay more attention to vulnerability. This means operating with increased flexibility and empathy. ‘A key aim of issuing the proposed Guidance is to help ensure that vulnerability is taken seriously by firms, and that it prompts action by firms to embed the fair treatment of vulnerable consumers into their culture, policies and processes throughout the whole consumer journey.’ The research highlights key themes in the fair treatment of vulnerable consumers. These are:

  • recognising vulnerability and responding to customers’ needs

  • the value of sympathy

  • the importance of empowered and knowledgeable staff

  • addressing communications needs

​Firms regulated by the FCA can now be asked to demonstrate the actions they have taken to:

  1. understand the needs of their target market/customer base,

  2. ensure their staff have the right skills and capability to respond to the needs of vulnerable customers,

  3. respond to consumer needs through product design, flexible customer service provision and communications,

  4. monitor that the needs of their vulnerable customers are being met and responded to, collect information on the impact of their policies and processes, and assess how they are resulting in good outcomes for vulnerable consumers.

​These key themes are embedded in Level’s ‘Vulnerable Customer’ and ‘Treating Customers Fairly’ policies and our culture and day-to-day operations. However, we are committed to actively listening, improving and making our service more inclusive. We work collaboratively with the law firms to provide the best possible service to clients who might be vulnerable – and we invite an ongoing conversation on how best to respond to the needs of vulnerable clients together. The FCA’s consultation period is 2 months and the deadline for responses to this Guidance consultation is 30 September 2020.



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