I’m a training evangelist, but its not a silver bullet for Consumer Duty

Peter Labrow, head of marketing at MorganAsh, explains why - in a Consumer Duty landscape - some training is needed and will play a critical role, but technology will be an integral part of meeting the requirements, especially in providing an objective assessment of vulnerability.

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Peter Labrow | MorganAsh
18th September 2023
Peter Labrow MorganAsh
"There are literally hundreds of potential vulnerabilities – and a passing bit of knowledge for each is nowhere near enough."

I’m a self-professed training evangelist. I don’t just have a passing interest in learning; it’s a subject I know about in real depth and one in which deeply believe.

I have been employed by training organisations at a senior level and worked with learning providers as a consultant. I co-founded a learning sector specific newswire, was a founding sponsor of the Learning and Performance Institute, I co-wrote a book about training – and have written countless articles for learning and HR magazines.

And yet, when it comes to applying training as the sole solution to assessing customers’ vulnerability for Consumer Duty, I’m really forced to say, “Woah there!”

It’s not that I don’t think training has a role to play. It does – and more knowledge is always a good thing. But as a panacea? I don’t think so. Why? There are three main stumbling blocks, and they’re interconnected.

Depth and breadth of training

The first is the depth and breadth of training needed to be sufficiently knowledgeable. There are literally hundreds of potential vulnerabilities – and a passing bit of knowledge for each is nowhere near enough. While you don’t need to be an expert, you do need some knowledge.

Take sight as an example. Like every vulnerability, people are not either blind or sighted. There are lots of conditions – and each has a range of severity. Typical of all vulnerabilities, many of these conditions will be of a severity that would require the vulnerability be recorded but doesn’t have a material impact on the person’s abilities to read. So, it would be potentially discriminatory – and may disadvantage them – to simply classify them as vulnerable.

Furthermore, like all vulnerabilities, it’s likely the person will have coping mechanisms in place. A fully or largely blind person may use braille or assistive technologies such as screen readers – so they can be potentially as able as most other people. In addition, people typically have a support network – a partner who helps, or friends and family. So, a ‘checkbox for vision’ isn’t helpful, especially if there isn’t a means of exploring how that vulnerability is mitigated.

Multiple vulnerabilities

The second is that vulnerabilities aren’t serial events. People can be, and are, affected by multiple things at the same time. Our experience at MorganAsh is that most people can cope fairly well with a single event – a bereavement, accident, divorce and so on. Yes, these can certainly render a person vulnerable, although these are generally temporary in nature. But lose your job at the same time your partner leaves and the sum vulnerability is greater than 1+1 because it will almost certainly affect that person’s mental health – in either the short or long term.

It follows then that any training must take not only each vulnerability into account, but also what happens when there are multiple vulnerabilities. Some permanent, some temporary, some with coping mechanisms and support networks – and some without. That’s a lot of stuff to learn.


With the best will in the world, who has the time to learn all of this – when it’s just a part of your job? It happens to be a part of the job where reporting and attestation is vital, but financial advisers and firms must be experts, frankly, in quite enough stuff already.

I believe that most people would just reject the idea of having to undertake the amount training that’s actually needed. They may take some training and believe that it’s enough, but you don’t know what you don’t know, as they say. I’ve been immersed in the topic of consumer vulnerability for about three years and can talk passionately and with some authority on it – but I’d feel uncomfortable positioning myself as an expert.

To expect an entire sector to learn this amount of information, when it’s not their specialism, is a bit naive.


As humans, most of our decisions are based on subjective judgements. True, greater knowledge almost always brings lesser subjectivity, but that’s not a given. Without in-depth training, we can only make assessments based on our life experience – and it’s not enough, not by a mile. A good training course can give us a broad understanding – I’m fully in support of this. But it will take far more training than is reasonable to be confident that subjectivity has been removed from the equation.

This is why I believe that training alone can’t solve the problem. And that’s coming from someone who has been banging on about training most of his working life.

Any solution should not only include technology, it should be underpinned by it. A technological solution should obviate much of the need for training, make assessments objectively and provide the data required for attestation. A system such as MARS – the MorganAsh Resilience System – does this and more. Advisers can walk clients through an assessment, or they can leave it entirely to MARS, taking themselves out of that part of the equation.

Some training is still needed and will play a crucial role. In my experience most people’s understanding of consumer vulnerability isn’t close to being as strong as it should be – a clear priority to address. But, with a technology solution, training doesn’t need to be in depth and shouldn’t take long. Training certainly shouldn’t be the sole solution.

I’m sure those long-term colleagues of mine in the L&D sector will instinctively disagree. I’d argue that if the only tool you have is a hammer, you’ll start treating every problem like a nail. I’m from an L&D background – and it’s taken me a good while to grasp the sheer scope of what’s needed.

I readily accept that technology isn’t the single solution either – but to assess and manage vulnerable clients objectively, quickly, easily and cheaply, it’s a much better proposition than training alone. And that’s coming from a training disciple.

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