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How is vulnerable customer identification faring in the consumer finance sector?

Author: Jonathan Barrett, CEO of Comentis

Consumer Duty, the Financial Conduct Authority’s (FCA) initiative to protect customers including those who are vulnerable, has been in place for a little over six months now. Jonathan Barrett, CEO of Comentis evaluates how consumer finance firms are coping with their vulnerability assessments and what the regulator will want to see next.

We’re six months in from the FCA’s Consumer Duty regulations coming into force, and in general, we’re seeing a mixed bag in terms of how firms are faring with their vulnerability assessments. Some firms are doing well and making traction, whilst others seem to be struggling somewhat.

Perhaps most worryingly of all, there still seem to be a small number of firms who feel that they don’t need to change their ways of working in line with their Consumer Duty obligations. Some, for instance, might think that being smaller means they’re safe from the Duty or that it doesn’t impact their sector specifically. But whilst it may be true that the FCA will focus most of its attention on the largest players, the regulator has been very clear that there will be no exceptions made, and likewise that no industry is exempt.

Consumer Duty – the requirement to protect customers, including those who are vulnerable – has a fundamental impact on all firms providing regulated financial products or services to consumers. It requires firms to act to deliver good outcomes for their retail customers and ultimately keep them safe.

Consumer Duty will have a fundamental impact on all retail consumer creditors offering a finance plan. Regardless of whether the purchase on credit is big or small, from buying a car to a pair of glasses, all firms must ensure they can identify each and every instance of vulnerability and provide ‘good outcomes’ for their customers and the appropriate support.

The impact of this on the UK consumer finance market is huge. Take the motor finance market for example, the rate at which cars are being bought on finance shows no sign of slowing, with the average sum borrowed in the UK for a new vehicle shooting up from £11,964 to £25,039 in the space of just 13 years.

With such large amounts being spent, and with the cost-of-living crisis putting household budgets under significant pressure, it’s vitally important that potential customers are accurately assessed for any risk of vulnerability before they’re offered any form of finance arrangement.

But what is vulnerability exactly?

The FCA defines vulnerability as:

“Customers who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Firms should think about vulnerability as a spectrum of risk. All customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to 4 key drivers.

• Health: health conditions or illnesses that affect ability to carry out day-to-day tasks.

• Life events: life events such as bereavement, job loss or relationship breakdown.

• Resilience: low ability to withstand financial or emotional shocks.

• Capability: low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy, or digital skills.”

Vulnerability could stem from illness, divorce or low resilience – triggers that have all been defined by the FCA – as well as from a threat to someone’s income or their suitability for credit. It’s the emotional, mental and cognitive response to these circumstances that leaves someone vulnerable, and as such, they must all be correctly identified.

Undoubtedly the identification process is complex, even for a trained clinician, but for sales professionals who lack an in-depth knowledge of the nature of vulnerability, identifying at-risk customers will prove an incredibly difficult task without technological support.

The other thing to keep in mind is that this is not a once said and done thing. Time and again the regulator has made it clear that Consumer Duty is not a one-off exercise, reminding us all that firms will need to make sure they are continuously learning and improving.

Nisha Arora, Director of Cross Cutting Policy and Strategy at FCA:

“It’s something that needs to become part of who you are as a firm, your culture, and how you do business, running across your whole organisation from Board to front-line delivery, from product design to communications and customer support.”

To do this though, data is key.  

Those that are starting to make traction have started to build up hard data on vulnerability. Six months in, we believe that there’s a real opportunity for these firms to assess what they’ve gathered so far, take stock, and see if their target market assumptions are playing out as expected. And if any vulnerabilities have been identified, they could also look at how well that individual customer has actually been supported. With this knowledge, they can then determine whether their preparations were fit for purpose or if there are changes required and then develop from there. Of course, the FCA is not expecting a transformation overnight, but it is expecting organisations to build their banks of vulnerability data and learn and adapt based on this.


The best way to achieve this is with data and a systematic process for screening clients and appropriate accommodations for the needs of those at risk. By combining clinical expertise with hard data, these kinds of solutions can remove bias and subjectivity from the process, ensure consistency across a whole client base and reassure firms that their systems will adequately meet the scrutiny of regulatory requirements.

In the long run, this is a process that will benefit everyone. If you’re struggling, or if you know that you need to bring in additional expertise, don’t delay any further.

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Business

Building Compliance into Business Culture is Essential in Fintech

Source: Finance Derivative

Tetyana Golovata, Head of Regulatory Compliance at IFX Payments

Regulation plays a critical role in shaping the fintech landscape. From Consumer Duty and FCA annual risk reporting to APP fraud, the tectonic plates of the sector are shifting and whether you consider these regulations as benefiting or hindering the industry, businesses are struggling to keep up. 

According to research by fraud prevention fintech Alloy, 93% of respondents said they found it challenging to meet compliance requirements, while in a new study by Davies a third of financial leaders (36%) said their firms had been penalised for compliance breaches in the year to June. With the FCA bringing in its operational resilience rules next March, it is more important than ever to ensure your company makes the grade on compliance. 

Lessons from history

Traditionally, FX has struggled with the challenge of reporting in an ever-developing sector. As regulatory bodies catch up and raise the bar on compliance, responsible providers must help the industry navigate the changes and upcoming deadlines.

Fintechs and payments companies are entering uncharted waters – facing pressure to beat rivals by offering more innovative products. When regulators have struggled to keep up in the past, gaps in legislation haveallowed some opportunists to slip between the net, as seen in the collapse of FTX. Because of this, implementation and standardisation of the rules is necessary to ensure that innovation remains seen as a force for good, and to help identify and stamp out illegal activity.

Culture vs business

Culture has become a prominent factor in regulatory news, with cases of large fines and public censure relating to cultural issues. As the FCA’s COO Emily Shepperd, shrewdly observed in a speech to the finance industry, “Culture is what you do when no one is looking”.

Top-level commitment is crucial when it comes to organisational culture. Conduct and culture are closely intertwined, and culture is not merely a tick-box exercise. It is not defined by perks like snack bars or Friday pizzas; rather, it should be demonstrated in every aspect of the organisation, including processes, people, counterparties, and third parties.

In recent years, regulatory focus has shifted from ethics to culture, recognising its crucial role in building market reputation, ensuring compliance with rules and regulations, boosting client confidence, and retaining employees. The evolving regulatory landscape has significantly impacted e-money and payments firms, with regulations strengthening each year. Each regulation carries elements of culture, as seen in:

  • Consumer duty: How do we treat our customers?
  • Operational resilience: How can we recover and prevent disruptions to our customers?
  • APP fraud: How do we protect our customers?

Key drivers of culture include implementing policies on remuneration, conflicts of interest, and whistleblowing, but for it to become embedded it must touch employees at every level.

This is showcased by senior stakeholders and heads of departments facilitating close relationships with colleagues across a company’s Sales, Operations, Tech and Product teams to build a collaborative environment. 

Finance firms must recognise the trust bestowed on them by their customers and ensure the protection of their investments and data is paramount. Consumer Duty may have been a wake-up call for some companies, but progressive regulation must always be embraced and their requirements seen as a baseline rather than a hurdle.

Similarly, the strengthening of operational resilience rules and the upcoming APP fraud regulation in October are to be welcomed, increasing transparency for customers. 

Compliance vs business 

Following regulatory laws is often viewed as a financial and resource drain, but without proper compliance, companies are vulnerable to situations where vast amounts of money can be lost quickly.

A case in point is the proposed reimbursal requirement for APP fraud, which will mean payment firms could face having to pay compensation of up to £415,000 per case.

Complying not only safeguards the client and their money, but also the business itself. About nine in ten (88%) financial services firms have reported an increased compliance cost over the past five years, according to research from SteelEye.  Embedding compliance earlier in business cultures can be beneficial in the long run, cutting the time and money needed to adapt to new regulations and preventing the stress of having to make wholesale changes rapidly. 

Building a cross-business compliance culture 

Compliance is a key principle at IFX, and we strive to be a champion in this area. In response to these challenges, the business restructured, establishing dedicated risk and regulatory departments, along with an internal audit function. 

Regulatory compliance aims to support innovation by developing and using new tools, standards, and approaches to foster innovation and ensure product safety, efficacy, and quality. It has helped the firm to navigate the regulatory landscape while driving growth and maintaining high standards.

This organisational shift allowed each business line to own its own risk, with department partaking in tailored workshops designed to identify existing, new, and potential risk exposure. Shared responsibility for compliance is the only way to create a culture which values it. We see this as a great way for organisations to drive innovation while sticking to the rules. 

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Business

How AI virtual assistants are transforming education and training

By Gregor Hofer, CEO and Co-founder at Rapport

What separates good doctors from excellent doctors, the type that might get five-star reviews if, like an Uber driver, their services were supported by a smartphone app?

Medical knowledge, expertise, and better outcomes are, of course, the most important factors. But – particularly when dealing with patients’ relatives, discussing risk assessment and imparting bad news – we shouldn’t underestimate the importance of bedside manner.

This might come naturally to some doctors but there are none for whom training isn’t useful, whether at medical school or on the job.

There will always be a place for real human interaction in this training, the type that involves role-play, with actors or colleagues playing out different scenarios that explore the most effective ways to handle difficult situations.

But what if this could be supplemented by more readily available and less resource-intensive experiences that simulate these training environments? And what if it could be applied across numerous sectors, industries and professions, of which there are a great many that could benefit from such an opportunity?

What might that mean for those instigating tricky conversations and, perhaps more importantly, those at the receiving end of them?

Advances in generative artificial intelligence – or GenAI – mean that these are no longer hypothetical questions.

There’s no limit to the type of person this technology could help, but we’ll review three – doctors, those working in corporate HR, and online students – to give a flavour of the benefits it brings.

Before we do, a quick word on how such applications work.

An overview of the technology

It all starts with data. With access to enough content, the type that you store and curate on your internal systems, large language models (LLMs) can be trained to find the most appropriate response to whatever user input they’re exposed to, whether in writing or spoken, and then you as a user can respond to that response, and so the cycle continues.

You’ll have experienced something similar using the likes of CharGPT, but because this is based on your own content, you’re more in control. (For simpler and more prescriptive scenarios, though, I’d add that with the best solutions, you can alternatively import predefined branching dialogue to keep your conversations on track.)

It doesn’t stop there, though; by tapping into a solution that’s supported by experts in linguistics and computer-aided animation, your colleagues can interact in real-time with avatars equipped with believable facial expressions, accurate lip-synching capabilities, natural gestures and the ability to detect emotions.

All of this adds to the user’s willing suspension of disbelief that they’re interacting with a real person, or AI avatar, thereby enhancing the effectiveness of their learning.

These innovations are reshaping how we approach learning and skill development in so many critical fields. We said we’d look at three. We’ll start by returning to medicine.

Medical training

AI assistants can supplement the way doctors are taught to break bad news to patients, one of the hardest things they’ll face in practice and, given its subjectivity, something that can’t easily be looked up in a textbook on anatomy or physiology.

As we said from the outset, this is easier for some doctors than others, but given the literal life-and-death nature of such conversations and the shattering impact that the death of a loved one can have on a relative, there’s always room to improve medics’ empathy and communication skills – which is exactly what this technology delivers.

By utilizing experiential AI tools, clinicians can better use their time, alleviate pressure, fatigue and burnout symptoms, and ultimately allow them to better serve their patients.

Corporate HR

In corporate HR, virtual assistants can significantly streamline and enhance the hiring and firing process, as well as any difficult conversation; whether it’s a tough review, a disciplinary hearing, letting down an employee about a promotion they’d applied for or any other scenario that might bring a bead of sweat to your forehead, it’s all about providing safe and cost-effective practice before doing it for real.

Tech research consulting firm Gartner recently found that more than three-quarters (76%) of HR leaders believe that if their organisation doesn’t adopt and implement AI solutions, such as generative AI, in the next 12 to 24 months, they’ll lag in organizational success compared to those that do, while 34% of HR leaders participating in their January benchmarking session said they were exploring potential use cases and opportunities when it came to generative AI.

If they do manage to adopt the right technology, the impact will be massive among those who deploy it wisely. After all, which company wouldn’t want to upskill its HR professionals in tangible soft skills such as empathy, communication, problem-solving, and conflict resolution in a controlled setting?

Online education

AI-powered tools can hugely boost student engagement in remote learning environments, and the research suggests that it comes close to rivalling in-person experiences. When you consider the staff-to-student ratios common in most educational settings, this should be no surprise – think how many students can fit into a lecture hall (even if they don’t always turn up!).

But we’re not necessarily talking about formal education; this applies equally to any informal setting in which someone needs to improve their education in some way.

With this technology, you can invent new ways to educate your students – or staff – by transforming lessons into experiences, using interactive characters reflective of the subject. This means you can increase user satisfaction and performance without compromising on content.

Whatever the scenario and whatever the use case, the chances are that if you have the right content in sufficient quantities, you can tap it for interactions that would otherwise be lacking in uniqueness or prohibitively expensive.

With AI virtual assistants, everyone’s a winner.

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Business

How GenAI is Shaping the Future of Compliance

Gabe Hopkins, Chief Product Officer, Ripjar

Generative AI or GenAI uses complex algorithms to create content, including imagery, music, text, and video with amazing results. Less well known are some of the ways in which it can transform data processing and task performance. This groundbreaking technology not only saves time, effort, and money, but has become a game-changer in enhancing operational efficiency and fostering innovation across various sectors.

However, some industries like anti-financial crime compliance – have been slow to adopt new innovations like GenAI, predominantly due to concerns over potential risks. In fact, they can even see it as a risk in itself. Legal, Compliance and Privacy leaders rank rapid GenAI adoption as their top issue in the next two years, all while other, less risk-averse organisations enjoy the upside of implementing GenAI in their systems.

This delay means many compliance teams are not taking advantage of AI tools that could revolutionise their processes and help them save up to 200 hours annually per user.

Entering the New Era of GenAI in Compliance

Teams in largely regulated sectors like banking and fintech face enormous pressures. Their responsibilities include identifying risks, such as sanctioned individuals and entities, updating policies to keep up with ever-evolving regulations, and handling expansive datasets. The high volume of this data makes manual reviews exhausting and susceptible to errors, which can lead to financial and reputational damage.

One way to overcome these challenges is by leveraging GenAI. For example, false positives – where a risk is raised incorrectly or false negatives, where a real risk is not flagged, are common issues caused by trying to deal with very high volumes of alerts and risk matches. Implementing GenAI can reduce these inaccuracies, significantly enhancing the efficiency and effectiveness of customer and counter-party screenings.

In practical terms, GenAI can reinvent how compliance tasks are performed. For instance, in drafting Suspicious Activity Report (SAR) narratives, where analysts need to justify suspicions in transactions, GenAI can help automate this writing process, combining human oversight with artificial efficiency. Platforms using GenAI excel in summarising vast amounts of data— crucial for tasks like screening adverse media, where they assist in identifying potential risks linked to negative information about clients.

 Understanding the Opportunities of GenAI and Overcoming Fears

For the compliance sector, it’s a crucial time to explore how to incorporate GenAI effectively and securely without undue risks. Dispelling fears about data misuse, the high costs of initial model setups, and the ‘black box’ nature of AI models are central to this transition. Teams are particularly cautious about sharing sensitive data and the hidden biases that AI might carry.

Yet, some strategies can counter these challenges. By choosing suitable models that ensure robust security and privacy and adjusting these models within a solid statistical framework, biases can be mitigated. However, organisations will need to turn to external expertise – whether data scientists or qualified vendors – to support them in training and correctly deploying AI tools.

The latest advancements in GenAI suggest that virtual analysts powered by this technology are achieving, and sometimes surpassing, human-level accuracy. Despite ongoing concerns, which may slow adoption rates, the evident potential benefits suggest a bright future for compliance teams using GenAI. These technological innovations promise not only to improve speed and efficiency but also to enhance the capability of teams to respond and adapt swiftly.

Embracing GenAI will not only significantly elevate the effectiveness of compliance operations but also safeguard organisations against potential pitfalls while maintaining trust and integrity in their industry practices.

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