Comentis launches Vulnerability Support Framework for all FCA-regulated firms

by | Apr 25, 2023

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With Consumer Duty looming, and many firms struggling to appropriately support vulnerable clients, Comentis has released a comprehensive framework, advising on the action required for some of the most widespread vulnerabilities identified through its online assessment tool.

Clinical reg tech provider, Comentis, today announces the launch of its Vulnerability Support Framework. Available to all professionals regulated by the FCA, the framework addresses a wide range of potential vulnerabilities, providing practical, clinically-based instructions for the complex process of supporting at-risk customers.

The FCA estimates that, at any one time, over 50% of the adult population is experiencing circumstances that could result in a vulnerability. However, many firms, once they have identified a potential vulnerability, struggle with how to provide appropriate support. With Consumer Duty taking effect on 31st July, threatening potential sanctions for those failing to ensure vulnerable customers receive good outcomes, this knowledge gap must be urgently addressed.

Comentis has developed the Vulnerability Support Framework in direct response to this challenge. With various external contributors joining those from Comentis to share their expertise, and with endorsements from a growing list of industry supporters, this comprehensive document contains immediate and long-term actions for a variety of potential risk factors. Ranging from divorce and bereavement to dementia and low resilience, the vulnerabilities addressed have been identified through Comentis’ online customer assessment tool as some of the most widespread.

By developing the framework, and releasing it to all, Comentis not only hopes that firms will be better equipped to provide vulnerable customers with the best possible outcomes, but also to encourage the raising of standards across the industry in respect of supporting clients in vulnerable circumstances.

John Somerville, Head of Financial Services, Professional Education at The London Institute of Banking & Finance, comments:

“As the work to identify vulnerable customers advances, so too do the complexities involved in knowing how to advise them appropriately. I have worked with Comentis on various awareness-raising initiatives and their clinical expertise has helped me understand this issue in a much deeper way. This support framework will not only help advisers to develop their own understanding of the complexities of vulnerability, but will also offer practical working solutions for challenging situations.”

Tim Farmer, Co-Founder and Clinical Director at Comentis, as well as the author of the Vulnerability Support Framework, comments: “Consumer Duty will place identifying and supporting vulnerable customers firmly at the centre of the FCA’s regulation. However, many firms are struggling with the support element of that process. We have therefore created this framework, bringing together best practices from a range of vulnerability specialists, to help determine those crucial next steps.

“What makes this framework so unique is that it’s very much intended as a practical tool, designed not only to educate and encourage the raising of standards, but also to provide clinically-informed, in-the-moment instruction for any professional who has identified a financial vulnerability or vulnerable circumstance. It’s also something we plan to build on, with further initiatives to ensure good outcomes for at-risk customers.”

The Vulnerability Support Framework is available via

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