Applying proportionality to customer vulnerability under the FCA's Consumer Duty

The UK's Financial Conduct Authority (FCA) expects firms to deliver good outcomes for retail customers, as defined within Consumer Duty. Central to the Duty is proportionality – which enables firms' approaches to match the nature of the product or service, characteristics of customers, role in the distribution chain, and size/resources of the firm, all under an objective test of reasonableness. Proportionality does not equal minimalism. It means fit-for-purpose governance, evidence, and controls which are scaled to risk and complexity – not doing less by default. The FCA is looking...