Regulated Financial Services

Senior manager responsibility for the fair treatment of vulnerable customers

Our experts Sonya Zywko, Alan Hughes and James Gliddon discuss why firms must focus on the fair treatment of vulnerable customers, in the context of high inflation and borrowing costs.

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In the context of high inflation and borrowing costs, regulatory scrutiny is intensifying.

Firms must focus on the fair treatment of vulnerable customers and senior managers need to oversee governance and procedures designed to identify and support these vulnerable customers effectively.

In conversation, our experts Sonya Zywko, James Gliddon and Alan Hughes discuss why this topic is particularly relevant now and the steps senior managers need to take and broader implications that need to be considered.

Relevancy of fair treatment of vulnerable customers

We discuss recent developments including the FCA’s ongoing review of the fair treatment of vulnerable customers.

What is a ‘vulnerable customer’?

We talk about the FCA’s definition of a “vulnerable customer”, related guidance and why it is difficult to apply in practice.

A brief overview of the senior managers’ and certification regime and individual accountability

We briefly re-cap on the background to the regime, the legal framework, key documentation and individual accountability.

Why do senior managers need to take interest?

We look to recent developments and what we see on the horizon.

Potential risks of falling short of best practice

We briefly summarise the risks senior managers must be aware of.

What can senior managers do to get a degree of reassurance?

We discuss some of the key takeaways from the decisions to date.

What are some of the broader considerations?

We talk about the broader definition of senior managers under the Economic Crime & Corporate Transparency Act 2023 where fraud is alleged and considerations during litigation where senior managers are a party and/or witness.

In summary

We summarise the discussion, together with some final thoughts.

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