Vulnerable Customers Policy Template

The 37-page Vulnerable Customers Policy is an FCA-aligned guide for identifying and supporting vulnerable customers under the Consumer Duty. Built on FG21/1, PRIN, and 2025 FCA updates, it ensures fair treatment and prevents harm, improving outcomes by up to 20% per recent reviews.

It outlines processes for identifying vulnerabilities, adapting interactions, and monitoring outcomes, with templates such as identification checklists and training logs. Supporting audits, SMCR accountability, and GDPR compliance, it fosters empathy and trust in the financial services sector.

Includes:

• Link to FCA Principles and Consumer Duty

• Defining Vulnerability

• Drivers of Vulnerability (with Examples)

• Assessing the Nature and Scale of Vulnerabilities

• Tools and Methods for Identification

• Ongoing Review of Customer Profiles

• Product Design and Development

• Testing and Launch

• Delivery and Customer Service

• Post-Sale Support and Review

• Training Requirements

• Recognition and Response Skills

• Support for Staff

• Enabling Disclosure and Recording Information

• Flexible Service Provision

• Inclusive Design and Communications

• Data Protection Considerations

• Key Metrics and Management Information (MI)

• Evaluating Effectiveness

• Identifying and Investigating Issues

• Proportionate Remedies

• Vulnerability Identification Checklist

• Staff Training Log Template

• Monitoring Review Template

• Examples of Vulnerability Drivers

• Dos and Don’ts when Dealing with and Meeting FCA Compliance Obligations for Vulnerable Customers