Vulnerable customers and financial services: what does the future hold?

Hogan Lovells

Hogan Lovells

[co-author: James Wilkinson]

The fair treatment of vulnerable customers is a key priority for the FCA. It is an important topic not least because the FCA considers that half of UK adults (25.6 million people) display one or more characteristics of potential vulnerability.

The FCA’s definition of a vulnerable customer is intentionally broad and captures anyone who “due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care“.

Vulnerability for these purposes can be both ‘actual’ and ‘potential’ and is dependent, to some degree at least, on the nature of a customer’s treatment by firms and the level of complexity of the products or services that a customer is engaging with as well as the customer’s personal circumstances.

It is clear that “vulnerability” is not a static state of affairs; instead, customers may move in and out of “vulnerability” as circumstances dictate. Vulnerable (or potentially vulnerable) customers are therefore likely to comprise a significant proportion of a firm’s customer base at any given time.

A number of current FCA initiatives are designed – in varying degrees – to address the issue of fair treatment of vulnerable customers in the financial services sector.

With this in mind, what (additional) protections for vulnerable customers is the FCA contemplating and what can financial services firms expect in this area?

What current FCA initiatives are addressing treatment of vulnerable customers?

Each of the following FCA initiatives touches on the treatment of vulnerable customers.

  1. FCA consultation on the fair treatment of vulnerable customers;
  2. FCA consultation on introducing a new duty of care on firms obliging them to exercise skill and care in the provision of services to consumers;
  3. FCA work on fair pricing in financial services; and
  4. FCA review of access to travel insurance for customers with pre-existing medical conditions.

(1) FCA Consultation on Fair Treatment of Vulnerable Customers

In July 2019, the FCA published a consultation on draft (non-Handbook) guidance for firms on the fair treatment of vulnerable customers. The draft guidance sets out the FCA’s (preliminary) view on what the Principles for Businesses require of financial services firms to ensure the fair treatment of vulnerable consumers.

Firms will want to review their policies and procedures against the draft guidance and address any gaps.

What’s the rationale?

According to the FCA’s 2017 Financial Lives Survey, half of UK adults (25.6 million people) display one or more characteristics of potential vulnerability. The FCA wants to see ‘doing the right thing for vulnerable consumers deeply embedded in the culture of firms‘.

While many firms have made significant progress in how they treat vulnerable consumers, the FCA believes there is room for improvement, and considers some firms’ behaviours are still leading to consumer harm.

The draft guidance focuses on consistency of outcomes for vulnerable retail consumers across the financial services sector and when compared with outcomes for other (non-vulnerable) retail consumers.

What is vulnerability?

The FCA defines a vulnerable consumer as ‘someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’ (Occasional Paper 8 on Consumer Vulnerability). The FCA points out that consumers’ circumstances are constantly changing and therefore vulnerability can be both ‘actual’ and ‘potential’.

A “Principles-based” approach; not prescriptive requirements

The FCA’s draft guidance does not specify a checklist of required actions. Instead it outlines ways in which firms can comply with the Principles and adapt their practices to the constantly changing landscape and consumers’ requirements. The guidance includes examples of good practice and case studies demonstrating good and poor practice, all developed from the FCA’s stakeholder engagement on vulnerability issues.

Which Principles for Businesses are particularly relevant?

The draft guidance sets out the five Principles which underpin the fair treatment of vulnerable customers:

  • Principle 2: Skill, care and diligence;
  • Principle 3: Management and control;
  • Principle 6: Customers’ interests (TCF);
  • Principle 7: Communications with clients;
  • Principle 9: Customers: relationships of trust.

Principle 6 is singled out as being key to underpinning the need for firms to take particular care in the treatment of vulnerable customers since the FCA expects compliance with Principal 6 to involve behaviours such as:

  • Products and services are designed to meet the needs of identified consumer groups and are targeted accordingly.
  • Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  • Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.

From understanding and upskilling to practical action

The draft guidance underlines the importance of understanding vulnerable consumers’ needs in the context of a particular target market and customer base. The FCA expects firms to ensure their staff have the right skills to deal with vulnerable consumers’ needs. The draft guidance explains what firms should be doing to treat vulnerable consumers fairly at different stages in the customer journey.

The draft guidance emphasizes the need for firms to translate their understanding of vulnerable consumers’ needs into practical action in terms of product and service design, customer service and communication. Firms also need to incorporate a continuous improvement process into their practices, to monitor customer outcomes and implement any necessary updates.

On-going FCA monitoring

Once finalised, the guidance will be used by the FCA – taking a ‘proportionate approach‘ – to monitor firms’ treatment of vulnerable consumers and to hold them to account if they breach the Principles. While the guidance will not be legally binding, the FCA expects firms to take on board the guidance and apply it in a way that is compatible with other legal and Handbook requirements relating to how firms treat vulnerable consumers (for example the Equality Act 2010).

What’s next?

The guidance will be consulted on in two stages. In the first stage, the FCA is seeking feedback on three particular areas:

  • whether the draft guidance covers the right issues and would provide firms with the right degree of clarity on what they should do to improve the outcomes for vulnerable consumers;
  • how the guidance could affect firms’ costs and the extent of benefits to vulnerable consumers from changes triggered by the guidance;
  • stakeholders’ views on whether the guidance, as part of the FCA’s regulatory framework, is sufficient to ensure firms take appropriate action to treat vulnerable consumers fairly, or whether additional policy interventions, such as additional rules, might be required.

In the light of the feedback to the first stage, the FCA plans to consult in a second stage on revised draft guidance, with an accompanying cost-benefit analysis. If the FCA considers further interventions are necessary, it would also consult on those in the second stage.

The FCA asked for comments on the first stage of the consultation to be submitted by 4 October 2019 and the consultation has now closed. The FCA will consider the consultation feedback and plans to issue a response during the first half of 2020.

(2) FCA Work on Duty of Care

The FCA is currently considering whether to introduce an express duty of care on firms obliging them to exercise skill and care in the provision of services to consumers. Stakeholder feedback published by the FCA has shown that stakeholders are divided on the issue. The FCA has not (at this stage) specified the exact legal form that such a duty might take. The current aim is to explore more generally whether and how consumer protection could be improved by introducing a formal duty.

The FCA is particularly interested in looking at where (if at all) the current framework falls short and whether a new duty could do more to help address conflicts of interest or give consumers better access to redress. The FCA has also invited views on the most appropriate method for implementing any new duty.

On 23 April 2019, the FCA published a feedback statement identifying the following options for improving the exercise by firms of due skill and care:

  • reviewing how the FCA applies the existing regulatory framework, particularly how it applies the Principles and how it communicates with firms about this; or
  • new or revised Principles to strengthen and clarify firms’ duties to consumers, including consideration of the potential merits and unintended consequences of a potential private right of action for breaches of Principles.

The FCA intends to publish a further paper (due Christmas 2019 at the earliest) seeking detailed views on specific options for change.

Private Members’ Bill

On 29 October 2019, in a further sign of this issue occupying the minds of legislators and regulators, Lord Sharkey introduced a Private Members’ Bill into the House of Lords, proposing that the Financial Services and Markets Act 2000 (“FSMA”) be amended to empower the FCA to introduce a duty of care owed by authorised persons to consumers in carrying out regulated activities under FSMA (the “Bill”). The Bill proposed that a duty of care be defined as an obligation to exercise reasonable care and skill when providing a product or service. However, given Parliament was dissolved on 6 November 2019, it remains to be seen what progress will ultimately be made with the Bill. In any case, it is not clear that the FCA would necessarily need any amendments to FSMA in order to act.

Vulnerable customers

This initiative does not address vulnerable customers specifically. However, any changes ultimately adopted by the FCA to increase consumer protection will also have an impact on firms’ treatment of vulnerable customers and are likely to increase firms’ obligations to ensure that they tailor their practices, procedures and products to the particular needs of vulnerable customers in order to demonstrate that they have exercised due care and skill in serving vulnerable customers.

(3) FCA Work on Fair Pricing in Financial Services

The FCA is undertaking a Market Study into general insurance pricing practices, designed to address concerns that pricing practices in the retail insurance sector may be causing consumer harm (particularly to vulnerable customers) or adversely impacting competition. In particular, the FCA is looking at the so-called “loyalty penalty” where longstanding customers are charged more for the same product than newer customers.

In October 2019 the FCA published an Interim Report, outlining “significant concerns” that the home and motor insurance markets “could work better and are not delivering good outcomes for all consumers.

In particular, the FCA found significant evidence of “loyalty pricing” and firms targeting price increases at those customers they considered less likely to switch provider. The FCA also identified that firms engage in a range of practices that could make it more difficult for consumers to make informed decisions and could raise barriers to switching.

Vulnerable customers and proposed remedies

Importantly, the Interim Report identifies a clear link between poor pricing practices and customer vulnerability, finding that 1 in 3 consumers in the FCA’s consumer research who paid high prices showed at least one characteristic of vulnerability.

In light of these findings, the FCA is considering a number of potential remedies. Options include measures such as banning certain pricing practices, automatic switching of customers from higher to lower prices (for the same product or service) and restrictions on how firms use customer factors to set prices and determine margins, as well as measures such as restricting the use of auto-renewals or requiring firms to publish information about their price differentials.

Whatever the ultimate outcome, given the link the FCA has identified between higher prices and customer vulnerability a key strand of the remedial measures adopted is likely to be ensuring that vulnerable customers do not pay more for the same product/service compared to non-vulnerable customers.

Next steps

The FCA has sought feedback on its Interim Report and expects to publish a final report in the early part of 2020 (alongside a consultation paper on any proposed remedies).

Firms should make sure that they are prepared for any remedies the FCA proposes by reviewing their existing pricing practices and their governance, control and oversight procedures for setting pricing practices, particularly as regards customers who display characteristics of vulnerability.

(4) FCA Review on Access to Travel Insurance for Customers with Pre-Existing Medical Conditions (“PEMCs”)

The FCA is also looking at how the travel insurance market works for people with pre-existing medical conditions.

A feedback statement published in June 2018 reported that there is a lack of quality information on alternative cover options available to consumers with health conditions, where they receive a high quote or are been refused cover.

The lack of transparency around pricing limits such consumers’ awareness about their options and can mean that they have difficulties in finding competitive insurance that is appropriate for their medical condition.

Consultation Paper on ‘Signposting’ Rule

In an attempt to find solutions to this problem, in July 2019 the FCA launched a consultation seeking views on a new ‘signposting’ rule which would require firms to signpost consumers to a directory of travel insurance firms that have the appetite and capability to cover consumers with more serious PEMCs.

The FCA proposes that firms will be required to signpost consumers in the following circumstances:

  • When a consumer is declined or otherwise not offered cover, or cover is cancelled mid-term, due to a PEMC;
  • When a consumer is offered cover with an exclusion for a PEMC that cannot be removed; and
  • When a consumer is offered cover with an additional loading to their base premium due to their PEMC.

The consultation was open until 15 September 2019 and is now closed. The FCA is currently considering the responses to the consultation and will publish a Policy Statement along with final rules in due course.

Renewed Agreement on Age and Insurance

In a further development, and as an indication of how the industry is approaching the broad subject of customer vulnerability, on 6 November 2019, the British Insurance Brokers’ Association (BIBA) announced that the Association of British Insurers (ABI) and the UK government have renewed their agreement on age and insurance.

The agreement applies to motor and travel insurance contracts entered into on or after 5 November 2019 that are private, voluntary and separate from an employment relationship. Under the agreement, if an insurer or insurance broker is unable to offer cover to an older motorist or traveller because their age is above any maximum age limit used by an insurer, the insurer or insurance broker should automatically refer the customer to an alternative provider who can meet their needs, or to a dedicated signposting service.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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