Neurodiversity at the heart of the FCA's Consumer Duty

by Johnny Timpson OBE, Supervisory Board Member of GAIN

GAIN welcomes the introduction of Consumer Duty and the FCA’s guidance and rules that will improve retail financial services customers understanding together with the value, service, support, and outcomes that they receive and experience. With more than one in seven consumers and colleagues in the UK neurodiverse; that is, they have conditions such as autism, ADHD, dyslexia and dyscalculia. Some, though not all, of our customers will have different needs when accessing financial services – which can make them susceptible to harm if firms are not acting with appropriate levels of awareness and care.

All retail financial services firms, including banks, investment houses, insurers, brokers and financial advisers, need to be considering neurodiverse customers in every decision they make. This encompassing communication, products, services, and customer interactions with the golden thread that links them being the lifetime customer journey that our clients experience. Whilst this might appear a daunting task, every journey starts with some first steps and a few follow...

Step one – Be neurodivergent aware and inclusive by design and this is where GAIN can assist.

It starts with us! There is no better way to understand the needs of our neurodiverse customers than empowering and enabling our neurodivergent colleagues and employees. Through our corporate membership GAIN is here to help you on your journey to becoming neuro-inclusive, by giving your the skills and support to enable neurodivergent employees to thrive in the workplace. As a membership hub we offer resources and partners to help you make the changes you need, not only will your business benefit from an increase in diversity of thought and creative problem solving but by reviewing how to support your employees, this will enable you to better understand how to serve your neurodivergent customers. Talk to one of the GAIN team about corporate membership at info@gaintogether.org and access our corporate member online hub at member.gaintogether.org.

Step two - Get to know your vulnerable customer.

‘Vulnerability’ encompasses a huge range of traits, needs, and considerations. The FCA describes a vulnerable customer as someone ‘especially susceptible to harm’ – and it specifically lists ‘characteristics of vulnerability’, including poor health, cognitive impairment, life events such as new caring responsibilities, low financial resilience, and poor literacy or numeracy skills.

Step three - Understand we’re all different, and that when you’ve meet one vulnerable or neurodivergent customer … You’ve met one vulnerable or neurodivergent customer.

This conversation goes well beyond regulation. People with different vulnerable conditions are likely to need different solutions. But people with the same conditions may well need different solutions too!

Step four – Don’t try and eat the elephant all at once.

Grappling with this issue can feel like trying to boil the ocean; there are so many different vulnerabilities and guidelines to follow. A realistic approach needs to focus on the feasible and impactful and there are lots of quick wins. Some relatively simple language and design solutions might include having an upfront view of the sign-up journey and questions that will be asked or product purchase process so people know how long it will take, better navigation and consistency so customers know their location in the journey, and building psychological safety, confidence and reducing anxiety by using language to normalise negative emotions; these are universal design changes which lead to better experiences for all customers. Bigger issues might need more user testing and complex design; this can come in time and working with the GAIN community to share and benefit from best practice can help.

Step five – Introducing ‘ drop kerb’ policies and practices can help everyone.

When it comes to neurodiversity and vulnerability, don’t think about this as solving a problem for a small minority. The latest FCA Financial Lives Survey (published 26/7/2023) puts it at around half ( 47%) of all UK consumers– but solutions introduced for one group often, as with drop kerbs, help everyone.

Increasing the amount of choice and clarity on offer, regardless of people’s vulnerabilities or lack thereof, will result in a happier, better served client. When organisations are lived experience informed, inclusive by design and cater for the breadth and diversity of their customers and colleagues by creating ecosystems where the can belong and thrive, they reap the rewards both commercially and culturally; with satisfied customers and colleagues underpinning successful businesses.

In closing and on behalf of the Group for Autism, Insurance, Investment and Neurodiversity, join us and let’s GAIN together.

Johnny Timpson OBE is a Supervisory Board Member and one of the original founders of GAIN. As a principal, business strategist, FRSA, NED with a portfolio of financial services, he has worked in academic and the 3rd sector within advisory/ambassadorial roles plus as a Financial Services Consumer Panel Member and Financial Inclusion Commissioner.