Vulnerable Customers
Can you prove vulnerable customers are receiving good outcomes?
TCC experts are helping firms identify risks, improve support and demonstrate fair outcomes for vulnerable customers.
The FCA expects firms to do more than identify vulnerability. They must demonstrate that vulnerable customers receive appropriate support, can access products and services effectively, understand communications and achieve outcomes comparable to other customers. TCC helps firms assess, design and strengthen vulnerability frameworks, customer journeys, governance, management information and outcome monitoring.
What we help with
Building confidence in vulnerable customer outcomes
When do firms typically come to TCC?
Organisations often engage TCC following internal reviews, Consumer Duty assessments, regulatory feedback or concerns that vulnerability processes may not be delivering the intended outcomes. We also support firms undertaking customer journey transformation, improving complaint handling arrangements, reviewing communications or strengthening governance frameworks. Increasingly, firms are looking beyond simple vulnerability identification and asking whether vulnerable customers are genuinely receiving the support they need.
What does a TCC engagement look like?
We begin by reviewing how vulnerability is identified, recorded, monitored and governed across the business. This includes assessing customer journeys, frontline processes, colleague capability, management information and outcome monitoring. We then benchmark current arrangements against FCA expectations and Consumer Duty requirements before designing practical recommendations that improve both compliance and customer experience.
What do clients receive at the end?
Clients receive a clear view of vulnerability risks, strengths and improvement opportunities across their organisation. Outputs may include vulnerability framework enhancements, customer journey assessments, communications reviews, management information improvements, governance recommendations, outcome testing methodologies and board-ready reporting. Most importantly, firms gain greater confidence that vulnerable customers are receiving appropriate support and that those outcomes can be evidenced.
Services covered
Helping firms evidence that vulnerable customers receive the support, understanding and outcomes the Duty requires
The FCA expects firms to do more than identify vulnerability. They must show that vulnerable customers receive appropriate support, can access products and services effectively, understand communications and achieve outcomes comparable to other customers. TCC combines specialist conduct expertise with managed services, flexible resourcing and technology-enabled monitoring to help organisations close assurance gaps and evidence good outcomes.
- Vulnerability framework reviews
- Consumer Duty vulnerability assessments
- Vulnerable customer outcome testing
- Customer journey reviews
- Customer support assessments
- Communication reviews and testing
- Foreseeable harm assessments
- Vulnerability governance reviews
- Board reporting and oversight
- MI and outcome monitoring frameworks
- Complaints and vulnerability reviews
- Vulnerability assurance reviews
- Quality assurance programmes
- Vulnerability training programmes
- Ongoing monitoring and assurance
Case studies
Our expertise in practice
Specialist resourcingStrategic resourcing: Complex claims handlingFrom suitability reviewers to technical SMEs and claims handlers, TCC rapidly deployed skilled resource across multiple workstreams to help meet fluctuating claims volumes and programme demands.Read more →
Specialist resourcingSpecialist resourcing: Strategic partnershipDiscover how TCC Group's 20+ year strategic alliance has delivered specialist resourcing at scale, supporting 300+ projects, 50+ clients across the UK, EMEA and APAC, 8,000+…Read more →
Compliance AI & RegTechProject rescued by RegTechUsing a combination of regulatory insight, automation and intelligent case management, TCC Group transformed a complex review involving more than one million customers, reducing remediation volumes…Read more →FAQs
Common questions
What does the FCA mean by a vulnerable customer?
The FCA defines vulnerability as a customer who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.
How does Consumer Duty relate to vulnerable customers?
Consumer Duty reinforces the obligation for firms to deliver good outcomes for all customers, including those in vulnerable circumstances. Firms should be able to demonstrate that vulnerable customers are receiving appropriate support and are not experiencing avoidable harm.
What are the most common weaknesses firms identify in vulnerability reviews?
Common issues include inconsistent identification processes, poor recording of vulnerability characteristics, weak management information, ineffective customer journeys, insufficient colleague training and limited evidence of customer outcomes.
How can firms evidence good outcomes for vulnerable customers?
Firms should combine customer outcome testing, management information, customer journey reviews, complaints analysis, quality assurance and governance reporting to understand whether vulnerable customers are receiving the support they need.
How often should firms review their vulnerability framework?
The FCA expects firms to keep vulnerability arrangements under regular review. Reviews should be undertaken whenever significant regulatory, business, customer or operational changes occur and should form part of wider Consumer Duty governance.
Can TCC assess customer journeys through a vulnerability lens?
Yes. We review end-to-end customer journeys to identify barriers, friction points, communication weaknesses and support gaps that may disproportionately affect vulnerable customers.
Can TCC help improve vulnerability governance and board reporting?
Yes. We help firms develop meaningful management information, outcome metrics and board reporting frameworks that provide clear oversight of vulnerability risks and customer outcomes.
Which sectors does TCC support?
We support firms across wealth management, pensions, banking, consumer credit, payments, insurance, motor finance and utilities, tailoring our reviews to sector-specific customer risks and regulatory expectations.
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