No doubt we’ve all heard quite enough about that particular tale, so let’s not linger.

Right, as the boss continues basking on foreign shores, it’s my turn to keep his metaphorical chair warm.


Treating customers fairly is, happily, firmly embedded in the industry. It sits quietly in the background, coughing occasionally to remind us of its presence. Over the last few years however, and particularly since the pension freedoms came into play, there’s been growing concern that it doesn’t go far enough, and that vulnerable customers are potentially suffering as a result.

By a curious coincidence the FCA’s launch of a new guidance consultation (GC19/3) on the fair treatment of vulnerable customers came on the same day as news that it has fined Standard Life Assurance Limited £30.7m for not acting in the interests of its non-advised annuity customers. Standard Life offered ‘large financial incentives’ for sales between 2008 and 2016, which led to customers potentially missing out on enhanced rates – a situation it is in the process of rectifying.

The FCA has previously defined a vulnerable consumer as one ‘who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’. Its 2017 Financial Lives Survey found that 50% of UK adults show at least one characteristic of being potentially vulnerable.


The good news is that most firms have already made decent progress in identifying and looking after vulnerable clients. The bad news, according to GC19/3, is that ‘some firms are clearly failing to consider the needs of vulnerable consumers, leading to harm’.

Those that are taking steps, not unreasonably, want a steer from the regulator. And that’s the point of this new consultation. This first stage offers draft guidance and questions whether that’s enough or if stronger intervention in the form of rules is required.

The objectives are to improve consistency of outcome for vulnerable consumers across the industry and embed ‘doing the right thing’ into business culture. These are great goals but far from straightforward.


Vulnerability is a topic advisers and providers can struggle to deal with. Challenges highlighted in the FCA’s engagement work with firms included:

  • It’s transient – vulnerability can creep up gradually (with age) or hit suddenly (through illness or bereavement). It can also be reversed with improved financial circumstances or recovery in whatever form.
  • It’s personal – firms are required to seek details that people don’t want to share and don’t understand why they should share. Online-only is a real hurdle here.
  • It can cause offence – labels rarely make people feel better about themselves.

And then there’s the GDPR to think about. How should this data be recorded and, if required, shared?

The consultation is open until 4 October. The FCA will then publish revised guidance and consult on any further interventions which may be needed. It’s a major step in the right direction but the Standard Life fine potentially highlights an additional group of vulnerable customers… those who don’t know what they don’t know.

Financial decisions (especially around retirement income) can be complex enough but poor internal cultures and leadership can mean that all customers – and not just those who we would define as ‘vulnerable’ – may be at risk of poor outcomes. In an ideal world we’d be raising standards for all and not just the vulnerable.


It’s an exciting time to be a lang cat and we’ve a few things on the go.

  • Our new paper, kindly sponsored by those good sorts at Scottish Widows, is all about how the path taken at retirement – and the subsequent cost – can have a real impact on the fund. It’s right here for your downloading pleasure.
  • We’ve partnered with a firm that is developing a workplace savings proposition and would like advisers and paraplanners to share their views through a survey, whether or not you already have a workplace service. You’ll find out more if you take part and we’ll share a playback of the data with participants down the line.
  • Tickets are now on sale for DEADx #6, which will be held at our favourite haunt (pun), The Crypt on the Green in London on Thursday 14 November. If you’re confident that you won’t have left the country in a Brexit-related humfle by then you can book your place here.
  • Finally, we’re equally stunned and touched by the response to our upcoming sponsored walk to raise funds for the Edinburgh Samaritans branch. Huge thanks to everyone who has already handed over cash for this brilliant group of people (the Samaritans, not us). In case you missed it – a herd of lang cats (including honorary cat Ollie Smith from Citywire), will be walking 20 miles from Dunfermline to lang cat HQ in Leith on 28 September with the aim of raising £5,000. All donations made here are very welcome. You never know when you or a loved one might need the Samaritans – if that ever happens, they’re always available on 116 123.

A slight change of musical pace this week. There’s a better than average chance that I’ll have considerably more free time as a result, but not to worry. Hope it makes you smile – always works for me.

Enjoy the rest of your week,