A recent Chartered Body Alliance global survey has revealed some stark realities regarding the treatment of customers in vulnerable circumstances, including that 33% of respondents working in financial services considered themselves to be vulnerable within the last 12 months.
The survey was undertaken by Chartered Body Alliance members between 4 August – 8 September 2021. A total of 1,637 responses were received.
Over the past 12 months, the majority of respondents (61%) said that they had either directly or indirectly supported a customer in vulnerable circumstances, while 75% had discussed the issues facing such customers within their team, either frequently or on occasion.
Respondents were asked if they had seen any examples of bad practice towards customers in vulnerable circumstances. Detailed, anonymous examples were provided by 356 respondents and included:
- elderly customers being directed to online complaint forms
- pushy salespeople
- misuse and lack of knowledge of lasting powers of attorney and Court of Protection orders
- overuse of automation and AI and a lack of availability of telephone contact
- a lack of empathy for bereaved customers
- poor response to instances of scamming and fraud
- lack of sensitivity to customers’ physical disabilities.
When asked about their firms’ policies and procedures around the treatment of customers in vulnerable circumstances, almost four fifths (80%) said that their organisation does have policies and procedures in place, while just over 10% did not.
However, a significantly lower percentage (58%) had received formal, structured training on the fair treatment of customers in vulnerable circumstances. Of those who had undergone training, only half (51%) had received it in the six months prior to the survey.
Two-thirds (65%) of respondents said their organisation had a formal definition of what it considered to be a customer in vulnerable circumstances, with just over half (55%) believing that their firm’s definition aligned closely with the FCA’s. A clear majority of respondents (74%) had no concerns about their ability to implement the FCA’s guidance, with just 6% saying that they did have such concerns. However, 12% said they were ‘somewhat’ concerned.
In terms of culture, almost 80% said that their employer had implemented or attempted to implement a work environment that embeds fair treatment of vulnerable customers; under 10% had not.
Asked how confident they felt in their ability to identify a customer in vulnerable circumstances, the respondents averaged 76%. A slightly higher score (77%) was given to their perceived ability to take appropriate action after identifying such a customer.
CISI CEO Simon Culhane, Chartered FCSI said: “Our report shows that the majority of professionals are seriously addressing their duties and responsibilities in this area as outlined in the FCA Guidance.
“But there is more to be done, as we can see from the examples cited as unacceptable, bad practices towards customers. Lack of empathy, overuse of automation and poor communication are themes we must address. The FCA Consumer Duty proposals specifically state that regulated firms should “put themselves in the shoes of others.” We acknowledge the gaps in knowledge, skills and behaviour which this survey has highlighted. We will start this process by producing an Alliance toolkit and a series of events for 2022, with round tables for well-being leads in member firms, to open the discussion on this survey outcome.
“The fact that 33% of respondents working in financial services also considered themselves vulnerable within the past 12 months has emphasised the importance of looking after our own member practitioners. We will be examining how we can expand the CISI mental health portal in particular to further support financial services professionals in this respect.”
Simon Thompson, Chartered Banker Institute Chief Executive said: “We welcome the findings of this report, which gives us some great insights into how our members feel about the treatment of their customers in vulnerable circumstances. Over the past 18 months, we’ve all faced the very real challenges of supporting customers, colleagues, loved ones – and ourselves – through the series of challenges presented by Covid. Yet throughout this difficult period, banks and bankers – and the members of the Chartered Body Alliance in particular – have continued to play key roles helping to rebuild businesses, communities and personal finances. During this period, we offered a number of free resources to assist our members in their day-to-day roles in dealing with vulnerable customers; but as these findings reveal, more needs to be done, and we encourage all employers to work with us to step up the training required, whilst also considering their employees’ wellbeing needs.”
Sian Fisher, CEO of the Chartered Insurance Institute, said: “If we think we are going to go through our whole lives avoiding a time when we fit the definition of ‘vulnerable’, we are kidding ourselves.
“Financial circumstances, ill health, disability and life events all mean that we are almost certain to go through a period in our lives when we are vulnerable. This research underlines how important it is for us all to have an inclusive approach to all customers, and not treat vulnerability as an ‘add on’ that only applies to a minority.”