Vulnerable customers for compliance consultants: scoring vulnerability before it ships
For a compliance consultant working across 10–30 client firms, the same gap appears everywhere: vulnerability considered but not documented. A fixed rubric pre-scores that gap before it ships.
What the FCA says about firm-level vulnerability evidence
The Consumer Duty expects every firm to act for vulnerable customers and to demonstrate it. The FCA's Consumer Duty pages and the firm-level examples in the Consumer Duty publications library set out what that demonstration looks like — a consistent, recorded consideration across the firm's book, not a scatter of judgement.
That is the consultant's seat: evidence first, remediation second. The same check run across every firm surfaces the firms with the gap and the exact files where it appears.
The four-part rubric, firm by firm
Characteristics checked
Which of the four drivers were considered for the client — health, life events, resilience, capability.
Outcome
Indicators identified or ruled out, recorded for every file, not just the flagged ones.
Reasoning
Why the conclusion was reached, grounded in the client's stated circumstances.
Mitigations
The adjustments made where indicators were found — communication, charges, reviews, or suitability changes.
The rubric approach scales because it is the same test for every firm. The output is a list of files to fix and a record of what was fixed — the evidence the firm and the FCA both want to see.
Worked example: pre-scoring ten firms
Two ways a review engagement can run. Anonymised and illustrative.
Before
Files read ad hoc, gaps raised in conversation, no record of which checks ran or what each firm was told. Six months later nobody can say what was reviewed or fixed.
After
The four-part check run across ten firms: characteristics, outcome, reasoning, mitigations. A gap list per firm with file references and owners; remediation tracked and re-scored; a one-page summary each firm can show. The firm walks into any request holding the evidence.
Common mistakes in consulting reviews
- No fixed rubric. Every firm scored differently, so the outputs cannot be compared and the engagement cannot show a consistent standard.
- Gaps without owners. Findings that no firm has accepted as action items drift into the next engagement unresolved.
- Remediation never re-scored. The fix happened in a meeting; the file still shows the gap.
- No summary the firm can show. The consultant's work is invisible unless each firm leaves with a record of what was checked and what was fixed.
The consulting output at a glance
| Deliverable | What it contains | Why the firm needs it |
|---|---|---|
| Scoring record | Every file scored against the four-part rubric. | Shows the same standard ran across the book. |
| Gap list | Files, gaps, owners, and target dates. | Turns findings into a tracked remediation plan. |
| Re-score record | The fixed files and the corrected outcomes. | Proves the loop closed, not just that it was opened. |
| Firm summary | A one-page account of the review and the fix. | The evidence the firm can show to a reviewer. |
Related reads
The rubric draws on the vulnerable customers hub. Score against the four-driver breakdown and hand each firm the one-paragraph documentation wording as the fix.
Frequently asked questions
How many files per firm should the consultant review?
Enough to represent the book, with the sample basis documented in the methodology. A handful of files chosen without a rationale is hard to defend; a stated basis — adviser tenure, product line, client segment — makes the same review defensible.
Does the rubric replace the consultant's judgement?
No. The rubric surfaces the gap; the consultant makes the call. Every score a reviewer sees is a flag supported by the file, with the human judgement recorded alongside it.
What should the firm receive at the end?
A gap list with owners, the remediation record, and a summary the firm can show — the firms that can demonstrate the fixed state are the ones that walk into a request already holding the evidence.
Your next step
Run the four-part rubric across one firm's files this week and deliver the gap list with owners — the record is the deliverable. Start a free trial or see pricing.