In September 2024, we partnered with leading vulnerable customer SMEs, Money Advice Trust, to host a webinar on effective training approaches for customers in vulnerable circumstances.
297 senior financial services professionals collectively submitted over 120 questions for our panel.
Analysis of these questions revealed a range of pressing concerns, including:
- How to design engaging and inspiring training content (22%).
- A lack of clarity on what constitutes “good” vulnerability training (18%).
- Difficulties in measuring and monitoring the effectiveness of training programs (16%).
- Challenges in empowering staff to better assess and identify vulnerability (16%).
- A need for greater clarity on FCA expectations (10%).
- Concerns about maintaining staff competence over time (8%).
While a majority of firms on the webinar acknowledged the need for more frequent and continuous training and effective assessment processes, current training approaches often rely on generic e-learning modules (51% tailored, 45% off-the-shelf) with little emphasis on post-training evaluation or measurement of effectiveness.
Perhaps most concerning is the frequency of training delivered. For roles outside specialist vulnerable customer teams, contact centre staff, and complaint handlers, training typically occurs less than once per year, with a minority of firms admitting to only providing one-off training, raising important questions about the sustainability and effectiveness of current training practices in meeting the FCA’s expectations.
We also asked webinar participants for feedback on role- and function-specific understanding of vulnerable customers in their firm, which revealed a disparity in confidence levels.
- Sales teams were identified as possessing the lowest level of understanding, a concerning finding given their direct interaction with customers.
- Other functions raising concerns include outsourced customer service, claims handling, collections, and product/service design teams – all areas where vulnerable customers may be particularly exposed.
- Conversely, risk and compliance teams were perceived as having a strong grasp of vulnerable customer issues.
In the FCA’s latest customers in vulnerable circumstances review, the regulator reiterated that firms need to ensure that vulnerable customer guidance is incorporated into product and service design teams. Their multi-firm research highlighted this is a major area of weakness, with the review finding that:
- Few firms are training product and service design staff on vulnerability – and training is not tailored to role. 50% of firms the FCA surveyed said staff training was not tailored in their firm.
- Most firms the FCA engaged with could not show how they had embedded the needs of customers in vulnerable circumstances into their product and service design processes.
- In their multi-firm work on firms’ outcomes monitoring, they found firms often relied on data that lacked breadth and granularity.
- Many firms pointed to actions they had taken to make improvements for customers in vulnerable circumstances. But FCA saw limited evidence of firms consistently reviewing the effectiveness of actions.
- FCA likes to see the wellbeing of frontline staff managed and improved and to make sure they are supported to have complex interactions with customers.
How Clever Nelly can help…
Improve & Evidence the Competence of Employees Supporting Vulnerable Customers
The FCA demands a culture that ensures firms provide equal treatment to both vulnerable and resilient customers. Clever Nelly helps you build that culture by guaranteeing demonstrable employee in-role competence, driving better outcomes for your customers and better experiences for your staff.
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