MorganAsh has launched a new gap analysis service designed to help financial services firms assess how effectively their customer vulnerability management aligns with recently updated industry guidance.
The service is available to firms across the sector and is intended to provide clarity on how existing approaches compare with the higher benchmark standards set out by the Chartered Insurance Institute (CII) and the Personal Finance Society (PFS), which have now been adopted by the Financial Ombudsman Service (FOS) as the de facto standard for vulnerability management.
The gap analysis reflects the latest guidance and focuses on key areas including identification, customer support, data and systems, lifecycle management, reporting and audit trail.
Each section is structured around targeted questions that allow firms to assess their current position and identify where further development or investment may be required.
MorganAsh states that since its introduction late last year, the vulnerability management guidance has been widely welcomed across financial services and is increasingly viewed as the accepted benchmark.
It is intended to provide firms with a practical framework for embedding the principles-based requirements of Consumer Duty, with a particular emphasis on systems, processes and data needed to identify, monitor, support and report on vulnerable customers and outcomes.
Andrew Gething, managing director of MorganAsh, said: “The CII guide is an excellent and thorough specification of what is required in vulnerability management to meet FCA Consumer Duty regulations.

“But we know many firms struggle to communicate the challenges of vulnerability across management. This gap analysis simplifies the requirements to 33 yes/no questions so firms can quickly and easily benchmark themselves against the standard and communicate this easily across management.
“With this higher benchmark now recognised and adopted as the standard by FOS, now is the time for firms to look at all areas of their approach to see how they compare.
“While very few firms are likely to meet all the criteria of the gap analysis, those who find themselves unable to meet multiple parts of this criteria will quickly see a need for improvement and further assistance.
“It’s an opportunity to really raise standards and processes — helping firms on the journey to leveraging the commercial benefits and competitive advantages of a regulation that encourages firms to know customers better, to tailor products and services, and deliver better outcomes.”
MorganAsh specialises in Consumer Duty and customer vulnerability and is best known for its MARS platform, which supports firms in understanding and monitoring vulnerable customers to help deliver good outcomes.
The platform is used across financial services and the utilities sector and enables organisations to adopt a consistent approach to identifying vulnerable characteristics, producing an objective resilience rating.
The guidance is available for download from the CII.




