The duty rules also made it very clear that firms can expect to be asked to demonstrate how their business model, the actions they have taken, and their culture ensure the fair treatment of all customers, including those in vulnerable circumstances.
To further emphasise the importance of this area, the regulator has stressed that firms should be aware that the way they supervise the treatment of vulnerable consumers will be integrated into their supervision and this is not a one-off supervisory exercise.
Furthermore, the regulator expects consumers with characteristics of vulnerability to benefit from the overall improvements in outcomes they expect to be delivered as a result of the new duty. The regulator has also used the duty rules to remind us that all customers are at risk of becoming vulnerable.
Richards adds: "As in its previous papers on vulnerability, the regulator reinforces the importance of embedding the fair treatment of those customers in vulnerable circumstances within a firm, and that all relevant staff should understand how their role affects their fair treatment.
“The duty rules make it very clear that firms can expect to be asked to demonstrate how their business model, the actions they have taken, and their culture ensure the fair treatment of all customers, including those in vulnerable circumstances."
No conflict with CII/PFS
The alliance, as Richards explains, is not intended to be a rival to the PFS or Pimfa.
He says the CDA is neither a trade body nor a commercial professional body or a subsidiary of another commercial organisation.
"Indeed, we will be sign-posting members to trade bodies such as Pimfa, Biba and IA etc, as well as professional bodies like the PFS, CISI and LIBF," he adds.
“To date we have been focused on launching the alliance and placing it on a secure financial footing. We have only engaged a limited number of firms and organisations pre-launch and will seek to engage more, including PFS/CII over the coming weeks.
“However, we were also sensitive to the current issues between the CII/PFS boards and felt that we should logically await the outcome of their member consultation before inviting them to join the alliance. Both the CII and PFS are of course listed bodies on our website.”
Objectives
The CDA will focus on the issue of vulnerability in the wider context of consumer duty.
As an independent, non-commercial body, Richards says the CDA will seek to differentiate itself by delivering:
