I've been struggling for a while now with the implications of the FCA's growing emphasis on vulnerable consumers, which first started to emerge when I worked there.
I've always accepted the significance of vulnerability, going back to the FSA's FinCap Survey of 2006. This includes my own experiences, both in the years just after I stopped being a student, and more recently when my parents passed away. However, I tended to see vulnerability as a minority state, assuming the vast majority of us weren't vulnerable at any given time.
But at last week's FCA follow up to their Mental Health TechSprint earlier in the year, I had a bit of a light bulb moment...
The event was held in partnership with the Mental Health Policy Institute, and the sprint itself had clearly been terrific. As usual, I began wondering about how to scale the great ideas on show across the industry, and how the results would be supervised on the ground. But this time these concerns became secondary, and instead I started making some connections...
- The FCA's recent papers on the 'Ageing population' paper and its "Approach to consumers"
- FPC concerns about high levels of unsecured credit and household debt
- Emerging Fintech-related issues around the assumptions underlying algorithms
Looking at these together, it now seems to me that at root we are virtually all financially vulnerable at some stage of our life. Due to some combination of long term factors and immediate circumstances, our own state and/or developments in the industry, few if any of us are immune.
All of which would raise some major questions for regulator and industry alike, including:
- if vulnerability requires more individual attention, what does it mean for detailed rule-making?
- how do firms meet suitability tests that seem in practice, quite possibly for good reasons, to be getting higher?
- where will the advancing tide of algorithms take us? Towards gradually narrowing circles of "normality", or towards a world where all decisions and all risk is individual? Neither extreme seems appealing.
The potential flexibility offered by RegTech (#FCAsprint, #MachineExecutableRR, #RegReporting) may deliver a decent part of the answers. If it can, the prize is a big one.
This TechSprint event supported our commitment to help consumers in vulnerable circumstances, including those with mental health problems, receive fair treatment from their financial services providers.