This IFS report on "Living standards, poverty and inequality" was released today as the Bank of England raised interest rates for the first time since it became illegal to smoke in pubs (July 2007). Put together with the recent IPPR Report on wealth inequalities. the result is a treacherous landscape for both firms and regulators.

A month ago, I posted some reflections by my colleague Alex Ellerton ('it's "obvious", isn't it') on the FCA's consultation on "creditworthiness in consumer credit" that seem even more pertinent now. Making assessments of customers' creditworthiness just got harder for firms, and finding effective and efficient ways to document their thinking acquired an extra premium (not least with SM&CR on the way).

For the FCA meanwhile, defining vulnerability, already as slippery as a bar of soap, also became even more difficult. Whatever the answer, it needs to be sufficiently straightforward and practical for supervisors to use on the ground.