The banks’ trade association, the British Bankers’ Association (BBA) , has published a list of nine high-level principles which it intends its members should follow in order to improve outcomes for customers in vulnerable circumstances.

• Sensitive, flexible response – When customers seek help and support, firms should treat them sensitively and flexibly and be responsive to their needs
• Effective access to support – Customers should be able to access practical, jargon-free information from their bank, and should also be informed about other organisations from which help may be available
• One-stop notice – customers should not need to keep reminding their bank about the specific circumstances that make them ‘vulnerable’ – the bank should have records of this and should be aware of the situation every time they deal with that particular customer
• Specialist help available – Customers should have access to specialist support to help them make informed choices in light of their vulnerability. Where customers require regular or ongoing assistance in such circumstances, firms should consider providing dedicated points of contact
• Easy for family and friends to support – Firms should make it easy for a friend or family member to help in managing the affairs of a vulnerable customer
• Scam protection – Customers at increased risk of falling victim to scams and swindles need greater protection from their bank
• Customer focused reviews – Firms’ evaluation and monitoring procedures should be focused around obtaining a positive outcome for the customer
• Industry alignment – The industry should, via the financial services trade associations and other bodies, work together to improve outcomes for customers in vulnerable situations
• Inclusive regulation – Regulators should provide more support to individual financial services firms and the wider industry to assist them in achieving better outcomes for vulnerable customers

The BBA will now take the following steps:

• The BBA’s Retail Policy Committee Vulnerability Sub Group will examine the recommendations with a view to implementing these within a realistic timeframe
• Other organisations will now consider incorporating some of these recommendations within their own codes of practice. Such bodies include the Lending Standards Board, who operate their own Lending Code, will bring the achievement of improved customer outcomes within their monitoring regime
• The BBA’s Consumer Panel will conduct a review in 12 months’ time to see what progress has been made in implementing the recommendations

Although the BBA’s recommendations relate specifically to the banking sector, all authorised firms should be aware of the need to have procedures in place to ensure vulnerable customers are treated fairly. Many of the nine principles listed above could be equally relevant to financial advisers, consumer credit firms etc. Customers may be ‘vulnerable’ due to any number of factors, which include:

• Financial difficulties
• Lack of experience of financial products and services
• Learning difficulties
• Mental or physical health issues
• English not being their first language
• Poor spoken and/or written communication skills in general
• Poor literacy and/or numeracy
• A major lifestyle change caused by bereavement, divorce or unemployment

The Financial Conduct Authority defines a vulnerable consumer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.