Paul Creighton-Williamson: Deep thinking required on client vulnerability
It s nearly two years since the Financial Conduct Authority (FCA) published its seminal ‘
Guidance Consultation 19-03 on the treatment of vulnerable customers and three months since the regulator concluded its final guidance entitled:
Both documents are lengthy, the final guidance document runs to a daunting 56 pages. However, it s one of the more critical areas for providers and advisers alike to get right, not least because in between the publication of the guidance consultation in mid-2019 and the arrival of FG21/1 in February 2021, the UK lost more than 120,000 of its people to Covid-19 and many thousands more have been rendered vulnerable as a result the effects of the pandemic.