In the current climate, our understanding of what it means to be vulnerable is shifting. Liz Hornby, Principal Consultant at LEO GRC, explores the ways that financial institutions can better focus on and deal with growing numbers of vulnerable customers, and how training solutions can help.
Financial services organizations across the globe are seeing an increase in newly vulnerable customers hit by the health or financial consequences of COVID-19.
In July 2020, the UK’s Financial Conduct Authority (FCA) estimated that over 24 million adults in the UK currently display at least one characteristic of vulnerability. That’s over a third of the population. Now is the right time to take a fresh look at how your firm deals with vulnerable customers.
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Protecting Vulnerable Customers Is a Priority for Regulators
The Financial Conduct Authority (FCA) has named vulnerability as one of its key areas of focus in its 2020/21 Business Plan.
US financial regulators, such as the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), have also put the protection of vulnerable customers at the top of their priority list.
The regulatory buzzwords here are “fairness” and “consistency”. Getting this right, however, goes beyond policies and procedures. Treating vulnerable customers fairly means embedding the right behaviors in your firm’s culture too. Indeed, the FCA has called for a “practical shift in firm behavior”.
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What Training Is Needed to Protect Vulnerable Customers?
Awareness and training have a major role to play at a cultural, policy, and procedural level. This is not only in terms of treating customers fairly, but also in demonstrating to regulators that staff are equipped and trained to deliver fair and consistent outcomes.
Effective training will ensure that staff:
- Understand the characteristics of vulnerability
- Know how vulnerability may impact their customers
- Understand their firm’s approach
- Know how to respond
- Have the opportunity to practice these skills in a safe environment
- Can engage in practical real-life scenarios
Working With Vulnerable Customers: How We Can Help
Understanding and working with vulnerable customers has been a key part of Governance, Risk, and Compliance (GRC) training for a long time. As we adjust to the “new normal”, it’s important that we shape it in a way that prioritizes supporting those who need it most.
At LEO GRC, we have over 15 years of experience offering expert-led GRC training as well as eLearning courses for all sectors. With a key focus on behavioral change, we work with corporate and governmental organizations and are proud to help many of the world’s leading financial services organizations to deliver global compliance training programs.
Whether you’re looking for an off-the-shelf GRC solution, a custom training program, or simply want some advice on how to shape your vulnerable customers’ training, get in touch with the team.
Liz Hornby, Compliance Expert
Liz joined LEO GRC in 2010 and works as an in-house Subject Matter Expert. Since joining LEO GRC, Liz has completed a Masters Degree in International Business Ethics and Corporate Governance from the University of London and recently completed a PhD on whistleblowing in the UK banking industry.
After studying at Nottingham and Cambridge Universities, Liz qualified as a barrister and went on to work for both the London Stock Exchange and The Securities Association (a predecessor of the Financial Conduct Authority). She then moved into compliance, working for Nomura International plc and Goldman Sachs, before becoming a compliance consultant in 1994. As a consultant, she advised and worked with a broad range of financial services firms.
Liz was Deputy Chairman of the Compliance Forum Committee of the Chartered Institute for Securities and Investments (CISI) for many years and is a part-time lecturer in Corporate Governance and Ethics at the University of London.