The Chartered Insurance Institute (CII), a professional body representing the insurance and personal finance sectors, has published a new guidance paper aimed at improving how firms identify and support vulnerable customers.
Released in partnership with the Personal Finance Society (PFS), the document has been welcomed by MorganAsh, a specialist in vulnerable customer management.
The guidance has been introduced to help firms convert the principle-based expectations of the Consumer Duty regime into practical steps.
Many insurance and personal finance firms have struggled to apply the Duty in day-to-day operations, prompting the CII and PFS to produce a structured, actionable framework.
The CII and its subsidiary the PFS provide standards, training and professional support to individuals and firms across the insurance, financial planning and personal finance markets. Their mission includes enhancing public trust and promoting best practice across the industry.
The new paper, Supporting vulnerable customers: a practical guide for insurance and personal finance firms, outlines how organisations can embed vulnerability processes, assess customer needs and improve outcomes.
It has been developed with input from Consumer Duty specialists, sector practitioners and people with lived experience of vulnerability, offering an approach that extends beyond regulatory requirements.
According to its contributors, the guidance moves the industry towards a more consistent and considered approach to managing vulnerability.
It aims to bridge the gap between high-level regulatory expectations and the operational realities facing firms. The paper has undergone extensive peer review to ensure it is relevant, robust and workable across diverse business models.
MorganAsh welcomed the publication and highlighted its own vulnerable customer management system, MARS.
The tool can operate as a standalone solution or integrate with other systems through an API, and is used alongside training workshops designed to help firms establish effective vulnerability strategies.
MorganAsh managing director Andrew Gething 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.”
Gething added, “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.”
CII chief executive Matthew Hill said, “Effective vulnerability management is about more than regulatory compliance, it’s about creating a fairer, more resilient system. Firms that embed the principles of this guide into their culture and operations will not only meet expectations, but also build stronger customer relationships and reputations.”
PFS president Carla Brown added, “I welcome this guidance as a significant step forward for our profession. 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.”
MorganAsh and Absolute Military chairman Johnny Timpson 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. I’ve long held that the test of our progress as an industry and profession together with the delivery of our professional body’s Royal Charter promise should not simply be measured in adding to the abundance of those we serve and/or improving their resilience to perils and shocks but importantly, in ensuring that the vulnerable customers we serve enjoy the same access, inclusion, protections and outcomes as anyone else.”
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