To educate and align industry practices relating to the treatment of vulnerable customers
There is a regulatory and moral imperative to ensure that people are treated appropriately when they deal with financial firms, taking into account whatever vulnerability they may have.
Almost everyone will either have been in a position of vulnerability in their lives, or is currently vulnerable, or will become so as they age or need to care for someone. Financial firms have been working to deliver a consistent standard of fair treatment of customers for many years, but only recently have the needs of vulnerable people become central to fair treatment considerations. Some firms are well advanced with their practices, whilst others are struggling to establish consistent processes and strategy, and need support to help them advance more quickly.
Goal/s: a) To manage the RADAR tool (to ensure it is fit for purpose against finalised FCA guidance); and b) To define, develop and share best practice.
Strategy: Facilitate input from charities/trade bodies/regulator/3rd party suppliers and create a framework for dealing with customers in different vulnerable situations and categories.
The working group is largely concerned with acting in an advisory capacity to TISA’s new Consumer Duty working groups and continues to meet on a quarterly basis to provide a forum for discussion and as a mechanism to engage with the third sector, such as charities. Recent speakers include the RNIB and Vulnerability Registration service.
TISA attended FCA round table to discuss FCA concerns around their findings of firms’ approach to identifying/supporting vulnerable customers and associated financial crime.
Recently provided educational sessions to members on lesser understood vulnerabilities such as Aphasia, neuro-divergence and borderline personality disorder.
Refresh of the Best Practice Guide is underway, which takes into account evolving understanding of potential vulnerabilities and adding new sections on the above topics as well as bereavement and ex-offenders. A guide for firms in dealing with bereavement process is underway, working with partners AGE UK and Estate Search.
Vulnerability Conference successfully held Q1 2025, with speakers from FCA who have been highly engaged with us on our customer vulnerability work. Attended their launch event on the
findings of their vulnerability review and in response, the group are now working on production of a Best Practice Guide linked to the outcomes.
Attended an industry roundtable to discuss the implications of meeting accessibility needs and the relationship to vulnerability, where these are not met. These discussions have been, in part, instigated by the new EU Accessibility Act which came into force July 2025, and goes further in prescribing the approach in comparison to the UK Disability Act 2010. TISA has agreed to lead the industry on this work, commencing September 2025.
Discussions are also underway with an organisation looking at undertaking research into cognitive decline, to span both Vulnerability and Pensions Groups.
Aberdeen Group
A J Bell Securities Limited
Aegon UK PLC
Altus Consulting
Ashurst Risk Advisory LLP
Aviva Plc
Aviva UK Insurance
Bank of Ireland
Baringa Partners LLP
BNY
Canada Life
Delta Financial Systems
Digital Moneybox
Equiniti Financial Services Limited (EFSL)
Equisoft
Euroclear
Fidelity International
Forester Life
Freetrade
Hargreaves Lansdown
HSBC Bank plc
Interactive Brokers (U.K.) Limited
Invesco
Investec Wealth & Investment Limited
James Sharp & Co
Janus Henderson
JPMorgan Asset Management
Link Group
LV=
M&G Investments
Monzo Bank Ltd
NatWest PLC
Northern Trust
OneFamily
Pinsent Masons LLP
Prudential
Quilter Cheviot Limited
Quilter PLC
RBC Brewin Dolphin
Scottish Widows Plc
Square 4 Partners Ltd
SS&C
St James’s Place Wealth Management
Tesco Bank
Thesis Asset Management
Wellhouse Consulting
Yealand Fund Services Limited
Sophie Legrand-Green, Head of Policy leads on this work
Chair: Helen Bellamy, Quilter
