MorganAsh has teamed up with FWD Research to further assist firms in meeting the vulnerability requirements of Consumer Duty.
FWD Research conducts specialist surveys across a firm’s client base to help understand the prevalence of vulnerability. This aligns with MARS – the MorganAsh Resilience System – which provides an objective and consistent way of assessing and monitoring vulnerable characteristics. Alongside real-time management information and reporting, MARS generates a Resilience Rating, much like a credit score.
The partnership brings together two complementary approaches which supports firms in delivering accurate and relevant management information for Consumer Duty board reports – due in July. The FCA has already encouraged firms to prioritise board reports as this, and the data behind it will be a key tool in determining a firm’s compliance with the rules.
The partnership comes as the FCA continues its review of how firms approach and treat customers in vulnerable circumstances. Previously, the FCA has voiced concerns about firms repackaging existing data or those firms that still report few or even zero vulnerable customers.
Andrew Gething (pictured), managing director of MorganAsh, said: “It’s really exciting to be joining forces with FWD Research to use two complementary approaches towards consumer vulnerability in a unified way. Both approaches have their own strengths and each works well with the other.
“Our partnership underscores how MorganAsh’s expertise in consumer vulnerability management software complements FWD Research’s capabilities in running customer outcomes and vulnerability surveys. Working together, we can provide comprehensive solutions to financial services firms to meet regulatory requirements – and better serve their customers.”
Martin Grimwood, consumer duty lead at FWD Research, added: “Our partnership with MorganAsh provides clients with a robust two-stage vulnerability evaluation framework. By combining two different but complementary approaches, the framework ensures that clients can first identify how prevalent different vulnerabilities are within a customer base, develop appropriate strategies, and then apply those strategies operationally to customers who need them most. We are delighted to be working with colleagues and MorganAsh, who are undoubtedly leaders in their field.”
The outputs from both objective vulnerability management and sample surveys meet three key requirements of the FCA. This includes measuring vulnerability and the prevalent characteristics, measuring outcomes based on the communications provided by the firm and identifying differences in outcomes – particularly between the vulnerable and the resilient/non-vulnerable.
All firms are required to assess consumers to understand their individual characteristics, to enable them to modify how they work with them to meet their individual needs. While the FCA’s own research states that 50 percent of consumers are vulnerable at any one time, firms don’t know which ones those are. The only practical approach to attempt to assess all consumers to identify the 50 percent. Doing this requires consistent data – so the individuals’ data can be collated for analysis and reporting – and this needs a systematic, objective methodology, of measuring consumer vulnerability.
