FCA strengthens position on vulnerability and Consumer Duty

09 June 2025

Dear Adviser,

I am sure you have not failed to notice the FCA's increased rhetoric around the link between successful deployment of consumer duty and vulnerability, most recently from Nick Hulme (FCA) who went so far to state:

"Vulnerability is the lens through which we are looking at firms’ overall implementation of the consumer duty. If a firm can’t get vulnerability right, particularly the identification, then how is it getting [its] target market [or] client segmentation right?’

This sentiment emphasises the need to have a robust process in place when it comes to identification, and this is where Comentis can add real value. Where Comentis is implemented, we usually see a 3 to 4 fold increase in those identified, plus a more granular break down of vulnerable circumstances, aiding any client segmentation process.

Our top 5 tips to identify your vulnerable clients

1. Check every client, even if you are sure they are not vulnerable. It is just as important to have record of why they are not vulnerable as it is to be able to prove if they are vulnerable and what you have done to support them. Also many vulnerabilities can remain hidden.
   
   
2. Understand whether their is a vulnerable circumstance and whether this is having an impact on them. Many vulnerable circumstances (such as hearing impairments) are well managed and even though should be recorded as a vulnerable circumstance, will not be a vulnerability requiring support.
   
   
3. Be sure to identify all vulnerabilities - one thing our data has told us is that very few vulnerable clients will only have a single vulnerability trigger or circumstance. quite often a life or health event will have a direct impact on a persons levels of resilience and even capability.
   
   
4. Don't have a one size fits all approach - everyone reacts differently to different vulnerability triggers, so even 2 clients with the same vulnerability, going through a divorce for instance, could react very differently. So once you have identified the vulnerability discuss further with your client to see how its effecting them (this is called the causative nexus).
   
   
5. Record everything - the final top tip is to make sure you record everything, whether is a vulnerability, whether there is not, how you supported your client and what outcomes were achieved.

Of course, you don't need to remember to do this yourself for every client, as Comentis allows you to assess every one of your clients, quickly and easily and with over 180,000 assessments already completed by advisers, you can rest assured this is a well proven solution.

For more information please do not hesitate to reach out to me directly or you can book an initial meeting here.

Kind regards
Jonathan
Jonathan Barrett - CEO