Consumer Duty does require firms to pay regard to the nature, scale and characteristics of consumer vulnerabilities – but in practical terms what are the implications of this? Consumer Duty is a principle-based regulation – so there isn’t a definitive checklist of practical actions. It’s largely up to firms how they go about things – even if there is no doubt about what they need to do. So, within this framework, how do you assess vulnerability – and does this mean you need to assess everyone? Is there an easier way to deal with people en masse? Andrew Gething and Tony Crane discuss this in detail.
