The Consumer Duty: A New Era of Fair Treatment for Vulnerable Customers

The global financial crisis of 2008 left a devastating impact on the world’s economy. One of the significant reasons for the crisis was the unethical practices of financial institutions, which led to a loss of trust among customers. As a result, regulators started imposing stricter regulations on financial institutions to restore confidence in the industry. In the UK, the Financial Conduct Authority (FCA) regulate financial services, and one of its initiatives was the introduction of Treating Customers Fairly (TCF) in 2007.

TCF aimed to ensure that financial institutions put their customers’ interests at the heart of their business and treat them fairly in all operations. Banks were among the first institutions to be subject to TCF, and they had to demonstrate that they followed the TCF principles in their operations. TCF required banks to be transparent, provide customers with clear information, and handle their complaints efficiently.

As a consequence of TCF, firms will be subject to a Consumer Duty by August 2023. The Consumer Duty is a more extensive and significant initiative than TCF and aims to protect vulnerable customers across all sectors of the economy. The Consumer Duty builds on the principles of TCF, but it goes further by introducing more rigorous obligations on firms to ensure that vulnerable consumers are treated fairly.

The Consumer Duty comprises three key elements:-

  • The first element is to act in the best interests of customers. This means that firms must prioritise their customers’ interests over their profits and must take steps to ensure that their products and services meet customers’ needs.
  • The second element is to take all reasonable steps to avoid customer harm. This means that firms must take steps to identify vulnerable customers and take steps to prevent them from being exploited or harmed by their products and services.
  • The third element is to enable customers to make informed decisions. This means that firms must provide clear and concise information to their customers and ensure they understand the risks and benefits of their products and services.

The Consumer Duty is a significant step forward in protecting vulnerable customers across all sectors of the economy. It will require firms to take a more proactive approach to ensure that their products and services meet the needs of their customers and do not harm them. The Consumer Duty will also increase transparency and accountability, and firms that fail to meet their obligations will be subject to regulatory action.

In conclusion, the Consumer Duty is a welcome initiative that will help to protect vulnerable customers and restore trust in the economy. It builds on the principles of TCF and goes further by introducing more rigorous obligations on firms to ensure that vulnerable consumers are treated fairly. By August 2023, firms will need to comply with the Consumer Duty, and it will be interesting to see how this will impact how firms operate and treat their customers.

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