In 2022 we expect the impact of lockdowns, quarantine and social isolation will continue to be felt, with more consumers potentially experiencing greater vulnerabilities. In order to prepare for the new year (and new normal), organisations should enhance their consideration and preparedness of vulnerability within their own business and of their consumers.
As 2022 commences, many industries are breathing a sigh of relief after several complex and comprehensive regulatory reforms have gone live while organisations are continuing to manage the impact of COVID. During this period of reflection, and whilst planning work schedules and priorities for 2022, it is important for organisations to plan their programs of work with a vulnerable consumer lens. In late 2021, the Independent Review of the Banking Code of Practice released its final report (the Report). The Report focused on how important it was for banking institutions to effectively identify, monitor and protect consumers experiencing vulnerability, including those under-recognised in our community, to create inclusive and accessible banking. The Report presented several recommendations to improve the Banking Code of Practice (the Code) and outlined implications for the Code from recent regulatory reforms. While the Code applies to banking institutions, some recommendations are industry agnostic and appropriate for the broader financial services sector to consider.
To aid organisations as they prepare for 2022, we explore below -
As 2022 commences, many industries are breathing a sigh of relief after several complex and comprehensive regulatory reforms have gone live. During this period of reflection however, it is important for organisations to plan their programs of work with a vulnerable consumer lens. It can be useful to look to the FCA’s guidance and United Kingdom model, where many organisations have effectively embedded vulnerability considerations across the value chain, rather than as a standalone concept.
We believe organisations that prepare now, and establish their business so consumers experiencing vulnerability are treated fairly, will be ready when recommendations in the Report are implemented in the Code and across the industry. More broadly, any organisation that considers what to pack will be in a better position when the journey begins to change the way Australian businesses approach consumers experiencing vulnerability.
If you would like to know more about how the Report could affect your organisation, or how to commence the above no-regrets activities, please contact us.
In our next blog we will explore further how organisations can identify, monitor, manage and support consumers experiencing vulnerability using data.