Financial Services FCA / Consumer Duty Vulnerability & Affordability

Customer Vulnerability & Affordability Assessment Platform

FCA-regulated transformation of customer vulnerability identification, affordability assessment, support-plan management, communication preferences, audit evidence, and fair customer outcome monitoring.

Assessment Time

45m → 15m

Review Compliance

58% → 92%

Repeat Disclosure Complaints

-50%

00 Summary 01 Problem 02 Stakeholders 03 AS-IS 04 TO-BE 05 Requirements 06 Process Diagrams 07 Risks 08 Deliverables 09 KPIs

00 — Executive Summary

A regulated financial-services firm needed a consistent operating model for vulnerable customer support and affordability assessment.

A UK financial services company was under increasing operational and regulatory pressure to improve how it identified, assessed, supported, and monitored customers in vulnerable circumstances.

Vulnerability disclosures, affordability concerns, arrears indicators, complaints, and support requests were handled across disconnected systems, creating inconsistent customer outcomes and weak audit visibility.

The organisation needed a platform that could identify vulnerability indicators, assess affordability risk, trigger tailored support workflows, and maintain clear evidence that customers were being treated fairly.

As Business Analyst, I led the discovery and process transformation initiative to design a customer vulnerability and affordability assessment platform aligned with FCA expectations around vulnerable customers and Consumer Duty outcomes.

The solution introduced structured vulnerability capture, affordability assessment workflows, support-plan creation, specialist-team referrals, communication preferences, audit logging, and management information dashboards.

The transformation improved consistency, reduced manual handling, strengthened compliance evidence, and helped the firm deliver better outcomes for customers at risk of financial harm.

01 — Business Problem

Vulnerability and affordability handling was inconsistent, fragmented, and difficult to evidence.

The firm had multiple customer-facing teams dealing with vulnerability and affordability issues, but there was no consistent operating model.

Customer vulnerability signals appeared through contact centre conversations, missed payments, complaints, affordability reviews, collections interactions, bereavement or power of attorney requests, digital self-disclosure forms, and third-party support notifications.

Vulnerability disclosures were not consistently recorded
Customers often had to repeat sensitive information to multiple agents
Affordability reviews were manually assessed using inconsistent criteria
Support options were applied unevenly across teams
Audit evidence was difficult to compile
Management lacked reliable MI on vulnerable customer outcomes
Communication preferences and reasonable adjustments were not always visible to frontline staff

This created regulatory and customer-risk exposure. The business needed a centralised platform that could make vulnerability and affordability handling consistent, traceable, and operationally manageable.

02 — Stakeholders

Customers

Fair treatment, privacy & appropriate support

Needed safe disclosure journeys, accessible communications, and support that reflected their circumstances.

Contact Centre Agents

Clear prompts & support workflows

Needed guided capture, visible reasonable adjustments, and consistent next-step support prompts.

Collections Team

Affordable repayment plans & risk controls

Needed structured affordability evidence and clear support options for customers in payment difficulty.

Vulnerable Customer Support Team

Specialist case handling

Needed referral workflows, support-plan monitoring, and review-date controls for complex cases.

Compliance Team

FCA alignment & audit evidence

Required evidence of fair treatment, decision traceability, Consumer Duty outcomes, and governance controls.

Risk Team

Customer harm & conduct risk monitoring

Needed reliable MI on customer harm indicators, affordability risk, and outcome trends.

Product Team

Ethical journey design

Focused on low-friction, accessible customer journeys without over-collection of sensitive data.

Complaints Team

Evidence for disputes and complaints

Needed clear case histories, decision trails, and support evidence for complaint handling.

Data Protection Officer

Sensitive personal data governance

Required data minimisation, access controls, consent controls, retention rules, and privacy safeguards.

IT & Engineering

Secure workflow and integration

Needed secure integration with CRM, collections, support-plan, audit, and dashboard services.

Senior Leadership

Regulatory confidence & operational performance

Needed stronger assurance, clearer MI, and measurable customer outcome improvements.

Stakeholder Conflicts

Product and operations wanted low-friction customer journeys.
Compliance and risk teams required stronger controls and evidence.
Collections teams needed commercially viable repayment workflows.
Vulnerable customer specialists pushed for more flexible support options.
Data protection stakeholders were cautious because vulnerability information can be sensitive.

BA Balancing Role

Defined a model that protected customers without excessive journey friction.
Avoided unnecessary collection of sensitive data.
Balanced customer support, conduct risk, operational practicality, and audit evidence.
Translated FCA-aligned expectations into practical business and system requirements.

03 — AS-IS Workflow

Customer Contacts Firm

Agent Identifies Possible Vulnerability

Manual CRM / Case Notes

Transfer to Collections, Complaints or Support

Manual Affordability Assessment

Support Selected by Agent Judgement

Manual Follow-Up Tracking

Separate Compliance Evidence

Manual MI Extracts

Key Pain Points

Customers had to repeat sensitive circumstances because information was not captured in a structured and reusable way.
Affordability outcomes varied by team, agent experience, and manual interpretation.
The firm struggled to prove why a support decision was made and whether it led to a fair outcome.
Leadership could not easily compare outcomes for vulnerable and non-vulnerable customers.
Agents did not always see communication preferences, reasonable adjustments, or existing support plans.
Processes were not strong enough to consistently evidence FCA expectations around support, communications, product/service design, and outcome monitoring.

Operational Impact

Repeat disclosure and poor customer experience.
Inconsistent affordability decisions.
Weak audit evidence for complaints and compliance reviews.
Manual support-plan tracking.
Limited vulnerable customer outcome MI.
Conduct, privacy, and regulatory risk exposure.

04 — TO-BE Solution

Centralised customer vulnerability and affordability platform with human review for complex cases.

The future-state solution introduced a centralised customer vulnerability and affordability platform.

The solution did not automate sensitive decisions blindly. It used structured rules and risk indicators to guide staff, while requiring human review for complex or high-risk cases.

The platform captured vulnerability categories, support needs, consent status, communication preferences, affordability data, support plans, specialist referrals, review dates, audit logs, and outcome dashboards.

Vulnerability Disclosure & Identification

Customers self-disclose vulnerability or agents identify vulnerability indicators during interactions.

Structured Vulnerability Capture

The system captures vulnerability category, support needs, consent status, and communication preferences.

Affordability Triggering

Assessments trigger when payment difficulty, arrears, or financial stress indicators are detected.

Guided Affordability Workflow

Income, expenditure, commitments, dependants, arrears, and risk indicators are captured consistently.

Support Recommendations

The platform calculates affordability outcomes and recommends suitable support options.

Specialist Referral

Specialist workflows trigger where vulnerability or customer harm risk is high.

Support Plan Monitoring

Support plans are created, reviewed, and monitored with review dates and responsible teams.

Outcome Monitoring & Audit

Dashboards monitor outcomes, SLA performance, repeat contacts, complaints, and support effectiveness.

05 — Requirements

Functional Requirements

The system must allow customers to self-disclose vulnerability through digital channels.
Agents must be able to record vulnerability indicators during customer interactions.
The platform must support vulnerability categories such as health, life events, resilience, and capability.
Users must capture consent where required.
The system must record what information can be shared, retained, and displayed to staff.
Sensitive notes must be access-controlled.
The platform must capture income, expenditure, debts, dependants, arrears, and financial commitments.
The system must calculate affordability indicators using configurable rules.
Staff must be able to record customer context and override recommendations with reason capture.
The platform must recommend appropriate support options.
Support plans must include review dates, actions, communication preferences, and responsible team.
High-risk cases must route to specialist teams.
Customers must be able to select preferred communication channels.
Reasonable adjustments must be visible to authorised staff.
Templates must support plain-language and accessible communication.
All vulnerability, affordability, support, and decision records must be auditable.
Dashboards must show outcomes, trends, support-plan effectiveness, complaints, and review compliance.

Non-Functional Requirements

Sensitive customer data must be encrypted in transit and at rest.
Role-based access controls must restrict access to vulnerability and affordability records.
The platform must support GDPR-compliant processing, retention, minimisation, and deletion rules.
The system must avoid unnecessary collection of sensitive data.
The platform must support FCA Consumer Duty and vulnerable customer evidence requirements.
Audit logs must be immutable and available for compliance reviews.
Customer-facing forms and communications must be accessible and written in plain language.
Support-plan alerts, review dates, and escalation triggers must operate reliably.
Failed notifications must support retry handling.
The platform must support multiple products, brands, and customer segments.

06 — Process Diagrams

AS-IS vulnerability handling workflowTO-BE vulnerability disclosure and support workflowCustomer self-disclosure journeyAgent-led vulnerability capture workflowAffordability assessment processSupport-plan creation and review workflowSpecialist referral workflowCollections hardship workflowComplaint-linked vulnerability processConsent and data-sharing workflowCommunication preference workflowOutcome monitoring and MI reporting flowCross-functional swimlane across customer, agent, collections, specialist support, compliance, risk, and complaintsData flow diagram across CRM, affordability engine, support-plan module, audit logs, and dashboards

Overview

Customer Vulnerability & Affordability Assessment Platform.

Design and implement a centralised platform to identify vulnerable customers, assess affordability, trigger tailored support workflows, record communication needs, and maintain audit evidence aligned with FCA Consumer Duty and vulnerable customer expectations.

Business Goals

Improve fair treatment of vulnerable customers
Standardise affordability assessments
Reduce repeat disclosure
Improve audit readiness
Reduce customer harm risk
Improve Consumer Duty outcome monitoring
Support ethical and accessible service design

Scope

IN SCOPE

Vulnerability disclosure capture
Agent-led vulnerability recording
Consent and data-sharing controls
Affordability assessment workflow
Support-plan creation and review
Specialist team referral
Collections hardship workflow
Communication preferences
Audit logging
Outcome monitoring dashboards
Complaint and compliance evidence support

OUT OF SCOPE

Credit-risk model replacement
Full CRM replacement
Debt-sale strategy redesign
Legal recoveries process redesign
Product pricing redesign

US-01Vulnerability Disclosure

As a customer, I want to disclose support needs through a safe and simple process so that the firm can adapt how it communicates and supports me.

US-02Agent Vulnerability Capture

As a contact centre agent, I want guided prompts to record vulnerability indicators so that customer needs are captured consistently and respectfully.

US-03Affordability Assessment

As a collections advisor, I want to complete a structured affordability assessment so that repayment or support options are based on the customer’s financial situation.

US-04Support Plan

As a vulnerable customer support specialist, I want to create and monitor support plans so that customers receive appropriate help and review follow-ups.

US-05Communication Preferences

As a customer, I want to choose accessible communication preferences so that I can understand and respond to important information.

US-06Compliance Evidence

As a compliance manager, I want auditable records of vulnerability and affordability decisions so that the firm can evidence fair treatment and good outcomes.

Feature

Vulnerability Capture

Given a customer discloses a vulnerability or support need, when an authorised user records the information, then the system must capture vulnerability category and support need.
The system must record consent status where required.
The system must apply role-based visibility rules.
The system must display relevant support prompts to authorised staff.
The system must log the action in the audit trail.

Feature

Affordability Assessment

Given a customer reports payment difficulty, when an affordability assessment is started, then the system must capture income, expenditure, debts, arrears, and commitments.
The system must calculate affordability indicators.
The system must recommend suitable support options.
The system must allow advisor override with reason capture.
The system must save the assessment against the customer profile.

Feature

Support Plan Review

Given a support plan is created, when a review date is reached, then the system must notify the responsible team.
The system must flag overdue reviews.
The system must allow outcome updates.
The system must retain review history for audit purposes.

Feature

Communication Preference

Given a customer selects communication preferences, when future communications are generated, then the system must use the preferred channel where available.
The system must apply accessible template rules.
The system must show preferences to authorised staff.
The system must log communication events.

Overview

Workflow artifacts across vulnerability disclosure, affordability assessment, support plans, consent, communication preferences, and outcome monitoring.

The process maps aligned customer-facing journeys, frontline capture, collections, specialist support, compliance, risk, complaints, and MI reporting workflows.

01Current State

AS-IS Vulnerability Handling Workflow

Mapped fragmented disclosure capture, manual notes, team transfers, and inconsistent support decisions.

AS-ISVulnerability

02Future State

TO-BE Vulnerability Disclosure & Support Workflow

Defined structured capture, consent, support prompts, referral, review dates, and audit logs.

TO-BESupport

03Customer Journey

Customer Self-Disclosure Journey

Mapped safe digital disclosure, consent, support needs, communication preferences, and customer reassurance.

Self-DisclosureConsent

04Frontline

Agent-Led Vulnerability Capture Workflow

Defined prompts, sensitive note handling, access controls, and next-best support actions.

AgentCapture

05Affordability

Affordability Assessment Process

Mapped income, expenditure, debts, arrears, commitments, indicators, recommendations, and overrides.

AffordabilityRules

06Support Plan

Support-Plan Creation & Review Workflow

Defined actions, owners, review dates, outcome updates, escalation, and audit history.

Support PlanReview

07Referral

Specialist Referral Workflow

Mapped high-risk triggers, specialist-team routing, handoff information, and case follow-up.

ReferralHigh Risk

08Collections

Collections Hardship Workflow

Mapped payment difficulty, affordability assessment, hardship support, and repayment-plan actions.

CollectionsHardship

09Complaints

Complaint-Linked Vulnerability Process

Mapped how vulnerability and affordability evidence supports complaint handling and fair outcome reviews.

ComplaintsEvidence

10Data Governance

Consent & Data-Sharing Workflow

Defined consent status, visibility, retention, access rules, and sensitive-data controls.

ConsentPrivacy

11Communication

Communication Preference Workflow

Mapped preferred channel, accessible templates, reasonable adjustments, and communication event logging.

AccessibilityComms

12MI

Outcome Monitoring & MI Reporting Flow

Mapped Consumer Duty dashboards, support-plan effectiveness, complaints, repeat contacts, and review compliance.

MIOutcomes

Transformation Assessment

Identifying gaps between free-text, inconsistent support handling and structured vulnerability, affordability, and outcome-management workflows.

The gap analysis highlighted repeat disclosure, manual assessments, weak audit evidence, limited MI, inconsistent consent controls, and staff guidance gaps.

Current State

Inconsistent

Free-text notes, manual assessments, and fragmented support handling.

Future State

Structured

Dependent on experience

→

TO-BE

Embedded prompts and decision support

Stakeholder Analysis

Mapping customer, frontline, collections, specialist support, compliance, risk, DPO, engineering, and leadership priorities.

The stakeholder matrix clarified role, interest, and influence across teams involved in fair treatment, affordability risk, privacy, audit evidence, operational workflows, and outcome monitoring.

Total Stakeholder Groups

11

Customers, frontline, specialist, risk, compliance, privacy, product, technical, and leadership teams.

High Influence Groups

7

Collections, specialist support, compliance, risk, DPO, IT & Engineering, and leadership.

Platform delivery and integrations

High Interest

High Influence

Senior Leadership

Regulatory and customer outcomes

High Interest

High Influence

High Priority Stakeholders

Medium Priority Stakeholders

Governance & Ownership

Defining accountability across discovery, vulnerability capture, affordability workflows, support plans, consent rules, compliance evidence, dashboards, UAT, and rollout.

The RACI matrix established ownership across BA, contact centre, collections, specialist support, compliance, risk, DPO, IT, and leadership.

RResponsible

AAccountable

CConsulted

IInformed

Activity	BA	Contact Centre	Collections	Specialist Support	Compliance	Risk	DPO	IT	Leadership
Discovery Workshops	R	C	C	C	C	C	C	C	I
AS-IS Process Mapping	R	C	C	C	C	I	I	I	I
Vulnerability Capture Design	R	C	C	A	C	C	C	C	I
Affordability Workflow Design	R	I	A	C	C	C	I	C	I
Consent and Data Rules	C	I	I	C	C	C	A	C	I
Support Plan Workflow	R	C	C	A	C	C	I	C	I
Compliance Evidence Requirements	C	I	C	C	A	C	C	C	I
Dashboard Requirements	R	C	C	C	C	A	I	C	I
UAT Coordination	R	C	C	A	C	C	C	C	I
Rollout Planning	R	C	C	C	C	C	C	C	A

Transformation Delivery Plan

Structuring phased delivery across regulatory alignment, AS-IS mapping, target operating model design, solution design, MVP build, specialist workflows, compliance layer, UAT, rollout, and continuous improvement.

The roadmap sequenced FCA and Consumer Duty alignment, current-state discovery, workflow design, platform delivery, compliance evidence, staff training, operational rollout, and outcome monitoring.

Phase 1

Discovery & Regulatory Alignment

Review FCA expectations, Consumer Duty outcomes, current vulnerability and affordability handling.

FCAConsumer DutyDiscovery

Phase 2

AS-IS Mapping

Map disclosure, affordability, collections, complaints, consent, and support-plan workflows.

AS-ISMappingWorkflows

Phase 3

Target Operating Model Design

Define roles, support categories, escalation paths, governance controls, and MI requirements.

TOMGovernanceMI

Phase 4

Solution Design

Design vulnerability capture, affordability assessment, support plans, consent controls, and dashboards.

SolutionConsentDashboards

Phase 5

MVP Build

Launch agent-led vulnerability capture, basic affordability assessment, and support-plan workflow.

MVPCaptureSupport Plan

Phase 6

Specialist Workflow Rollout

Add referrals, high-risk case handling, review dates, and communication preferences.

ReferralHigh RiskPreferences

Phase 7

Compliance & Audit Layer

Add audit logs, evidence exports, consent rules, and outcome monitoring dashboards.

AuditEvidenceOutcomes

Phase 8

UAT & Staff Training

Test workflows, edge cases, data access, and frontline guidance.

UATTrainingAccess

Phase 9

Phased Rollout

Deploy across contact centre, collections, complaints, and specialist support teams.

RolloutCollectionsComplaints

Phase 10

Continuous Improvement

Monitor outcomes, tune support rules, improve communications, and refine MI reporting.

MIOutcomesImprovement

09 — Outcomes & KPIs

+65%

Vulnerability disclosure capture consistency improved from low baseline

15m

Affordability assessment completion time reduced from 45 minutes

-50%

Repeat disclosure complaints reduced

Lower

Manual support-plan tracking reduced significantly

Centralised

Vulnerable customer outcome MI moved from limited to dashboard-driven visibility

92%

Support-plan review compliance improved from 58%

Same Day

Complaint evidence preparation time reduced from several days

Standardised

Customers routed to appropriate support through consistent workflow

The transformation improved customer support consistency, reduced operational risk, strengthened audit readiness, and helped the firm evidence fairer outcomes for customers in vulnerable circumstances.