In July 2023 the FCA’s Consumer Duty finally took effect. In the following blog for IFA Magazine, Jess Trueman (pictured) of Smart Money People tells us why closing the gap between intention and action on customer vulnerability is crucial and how advisers can play a pivotal role in delivering fairer, more inclusive outcomes.
As we approach the second anniversary of the FCA’s Consumer Duty, it’s encouraging to see there is greater focus across the financial services industry around the importance of supporting customers in vulnerable situations.
Greater focus alone isn’t enough
But while the conversation is moving in the right direction, the latest FCA data makes it clear that greater focus alone isn’t enough. Firms are expected to actively monitor outcomes and implement services that are inclusive by design, not just by policy.
Understanding what’s happening in practice
Over the past year at Smart Money People, we’ve been exploring how this is playing out in practice. Through conversations, surveys and feedback from both professionals and consumers, we’ve been able to get a clearer picture of where progress is being made, and where more support is still needed.
The gap between intention and implementation
One area that consistently stands out is the gap between intention and implementation. Across the advice sector, there’s a shared commitment to doing the right thing, but also a recognition that vulnerability is complex. It’s not always visible, and it’s not always disclosed. That makes the role of well-trained advisers and flexible systems all the more important.
Brokers want better guidance and tools
In a cross-industry survey we ran in partnership with a UK building society, we heard from mortgage brokers about their confidence in recognising and supporting vulnerability. Many shared that they’d welcome more guidance and tools, digital and otherwise, to help them deliver consistent support in practice. There was also a clear call for better communication channels and clearer processes between intermediaries and lenders when it comes to sharing information about customer needs.
Consumers don’t yet feel significant change
But it’s not just professionals who are calling for change. Consumers, too, are telling us that while the principles behind Consumer Duty are welcome, they haven’t yet felt a significant shift in how they’re supported, especially those who identify as being in vulnerable circumstances.
Access to informed, compassionate people matters most
In a national survey Smart Money People conducted in 2024, a large proportion of customers in this group told us that their experience of financial services hadn’t improved since the Duty came into effect. What they valued most was straightforward access to real people who are informed, compassionate, and able to offer help when it matters. That kind of human-centred support remains critical, especially in moments of financial stress or life change.
Good outcomes require more than compliance
The FCA has been clear that supporting customers in vulnerable situations isn’t a compliance exercise, it’s a fundamental part of delivering good outcomes. This includes designing services that can flex to different needs, monitoring whether certain groups are receiving worse outcomes than others, and taking action where gaps are identified.
Turning feedback into practical insight
At Smart Money People, our work centres on turning feedback into practical insight. We help financial services companies see what’s working well and where they might need to improve, especially when it comes to the experience of vulnerable customers.
Moving from awareness to embedded action
As Consumer Duty moves into its third year, the challenge is to build on the foundations that have already been laid. That means moving beyond awareness and policy into consistent, embedded action — putting the needs of vulnerable customers at the heart of everyday decision-making.
Supporting vulnerability is essential for a fair sector
Vulnerability isn’t a one-off consideration. It’s a reality that many people will face at some point in their lives. And supporting those customers well isn’t just the right thing to do, it’s essential for a fair and resilient financial services sector.
