The service is available to firms across financial services and is intended to assess how existing policies, systems and processes align with guidance published by the Chartered Insurance Institute and Personal Finance Society. The guidance has been adopted by the Financial Ombudsman Service as the benchmark standard for vulnerability management.
The gap analysis is structured around key areas set out in the guidance, including identification of vulnerable customers, customer support, data and systems, lifecycle management, reporting and audit trail. Firms are assessed through a series of questions designed to highlight areas where further development or investment may be required. The company said its gap analysis can be used alongside existing systems or as part of a wider review of vulnerability management frameworks.
The vulnerability management guidance was introduced late last year and has been widely referenced across the sector. It is intended to support firms in meeting Consumer Duty requirements by setting out expectations around systems, processes and data needed to identify, monitor and support customers in vulnerable circumstances.
Andrew Gething, managing director of MorganAsh (pictured), said:
“The CII guide is an excellent and thorough specification of what is required in vulnerability management to meet FCA Consumer Duty regulations. But we know many firms struggle to communicate the challenges of vulnerability across management. This gap analysis simplifies the requirements to 33 yes or no questions so firms can quickly and easily benchmark themselves against the standard and communicate this easily across management.
“With this higher benchmark now recognised and adopted as the standard by FOS, now is the time for firms to look at all areas of their approach to see how they compare. While very few firms are likely to meet all the criteria of the gap analysis, those who find themselves unable to meet multiple parts of this criteria will quickly see a need for improvement and further assistance. It’s an opportunity to really raise standards and processes – helping firms on the journey to leveraging the commercial benefits and competitive advantages of a regulation that encourages firms to know customers better, to tailor products and services, and deliver better outcomes.”
