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Vulnerable Customers: Compliance Problem or a Cultural and Strategic Imperative?

21 May 2019

by Megan Walsh

Customer vulnerability can manifest itself in many ways, but how do you identify and define a vulnerability when your only point of contact with customers is over the phone or from behind a computer screen?

The Financial Conduct Authority has defined a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”.

And in an age where the value of face-to-face conversation and real-life human interaction comes second best to the convenience of phone calls and digital processes, the importance of properly identifying a vulnerable customer is more important than ever before.

This pertinent topic is something we discussed at our recent peer-to-peer Round Table event, in which 14 industry leaders came together to debate the most pressing matters facing the finance world.

Leading this topic discussion was Director of PwC, Sarah Nield, who was interested to hear from fellow risk and compliance leaders whether vulnerable customers are a compliance problem or a cultural and strategic imperative.

After the event, Richard Ollerton, Manager of Risk & Compliance at Oliver James, caught up with Sarah to record an exclusive podcast discussing her key findings from the discussion.

Compliance problem or a cultural and strategic imperative?

Sarah believes there is more that could be done, and companies need to provide proper training for their staff. Put simply, if you go down the strict compliance route then you’re not helping staff emphasize with customers – you can’t take a one-size fits all approach to this issue.

“There is more that needs to be done from a strategic perspective,” said Sarah. “It seems to be that firms have a set list of products and a set list of ways to do things, but they could be doing more to help those vulnerable customers in a different way than currently exists.”

What’s crucial to remember is that the person at the other end of the phone, or the other side of the computer screen, is a person. The issue of the vulnerable customer is not just a compliance or finance problem, it’s a customer – and you must be able to find the right outcome for that individual.

We’ll be releasing the podcast in the upcoming weeks, where you’ll be able to hear from Sarah Nield and fellow compliance leader Julian Davenport, so keep your eyes peeled for its release. These events bring together top industry leaders to explore the complex issues currently facing the compliance market. If you have a topic you think should be discussed, contact Richard Ollerton at or give him a call at (+44) 161 694 0779.

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