Vulnerable Customers Working Group

To educate and align industry practices relating to the treatment of vulnerable customers

Industry challenge

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.

Group purpose

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.


Vulnerable Customers Best Practice

Group strategy

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.

A guide for firms in dealing with bereavement process is underway, working with partners AGE UK and Estate Search.

Vulnerability Conference is planned for Q1 2024.

Participating member firms

A J Bell Securities Limited


Aegon UK PLC

Altus Consulting

Ashurst Risk Advisory LLP

Aviva Plc

Aviva UK Insurance

Baillie Gifford & Co

Bank of Ireland

Baringa Partners LLP

BNY Mellon

Comentis Ltd


Delta Financial Systems

Digital Moneybox




Fidelity International

Forester Life


Hargreaves Lansdown

HSBC Bank plc


Investec Wealth & Investment Limited

James Sharp & Co

Janus Henderson

JPMorgan Asset Management

Link Group


M&G Investments

NatWest PLC


Northern Trust


Pinsent Masons LLP


Quilter Cheviot Limited

Quilter PLC

RBC Brewin Dolphin

Scottish Widows Plc


St James’s Place Wealth Management

Tesco Bank

Thesis Asset Management


Lisa Laybourn, Head of Technical Policy and Risk leads on this work at TISA

Chair: Dimpel Patel, RBC Brewin Dolphin

Deputy Chair: Helen Bellamy, Quilter

If you are a TISA member who would like to get involved with the Vulnerable Customers work, please get in touch

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