Paul Creighton-Williamson: Deep thinking required on client vulnerability

It's nearly two years since the Financial Conduct Authority (FCA) published its seminal ‘Guidance Consultation 19-03' on the treatment of vulnerable customers and three months since the regulator concluded its final guidance entitled: ‘FG21/1 Guidance for firms on the fair treatment of vulnerable customers'. Both documents are lengthy, the final guidance document runs to a daunting 56 pages. However, it's one of the more critical areas for providers and advisers alike to get right, not least because in between the publication of the guidance consultation in mid-2019 and the arrival of F...