MorganAsh has welcomed the publication of new customer vulnerability guidance from the Chartered Insurance Institute and the Personal Finance Society, describing it as a material step forward for the insurance and personal finance sectors.
The paper, Supporting vulnerable customers: a practical guide for insurance and personal finance firms, is intended to help firms move from the principle-based requirements of Consumer Duty to a clear operational framework.
It has been developed with input from contributors across financial services, including specialists in Consumer Duty and those with direct experience of customer vulnerability. The content has also been peer-reviewed and shaped by people with lived experience.
Andrew Gething, managing director of MorganAsh and a contributor to the publication, said the firm fully endorses the initiative and its practical value for insurers, advisers and wealth managers.
He said: “This guidance is a real step forward.
“It’s comprehensive, detailed and practical. A lot of firms have found the principle-based Consumer Duty to be difficult to translate into practice, having been used to more prescriptive legislation. However, the principles provide immense freedom for firms to implement the Duty intelligently and in their own way.
“This is a kind of roadmap which shows firms the most effective routes towards unlocking Consumer Duty’s principles and show what they can mean in practice.”
FRAMEWORK FOR PRACTICAL APPLICATION
MorganAsh provides the MARS customer vulnerability management system, which can operate as a standalone tool or integrate with existing platforms. The business also runs workshops designed to support firms as they develop their internal vulnerability strategies.
Gething (pictured) said firms would benefit from the new publication, particularly because it goes further than previous summaries of FCA expectations.
He said: “The guidance will help a lot of firms. Everyone in the sector should read it.
“Unlike a lot of previous third-party guidance, which simply repackages what the FCA says, this is entirely new content. I know that this will lead to transformational thinking in the sector.”
SECTOR SUPPORT
Matthew Hill, chief executive of the CII, said: “Effective vulnerability management is about more than regulatory compliance, it’s about creating a fairer, more resilient system.”
He added that firms embedding the principles of the guide would strengthen both customer outcomes and their own reputations.
Carla Brown, president of the PFS, said: “I welcome this guidance as a significant step forward for our profession.”
She added: “Supporting clients in vulnerable circumstances is fundamental to good financial planning, and this practical framework gives firms clear direction on how to embed that responsibility into everyday practice.
“Our community is committed to raising standards and ensuring that every client, whatever their situation, receives the care, understanding and outcomes they deserve.
“This publication will help professionals across the sector strengthen their approach and, ultimately, deliver better experiences for the people who rely on us most.”
Johnny Timpson, chairman of MorganAsh and Absolute Military, said: “As a Financial Inclusion Commissioner and as Chair of specialist armed forces broker Absolute Military, I welcome the Chartered Insurance Institute’s Vulnerable Customer Guidance that supports the ambition of the Government’s Financial Inclusion Strategy and FCA Consumer Duty Regulation.”
He added that the industry should be measured not only on resilience and protection but also on ensuring equal outcomes for vulnerable customers.
The guidance is available to download from the CII.
