The Government is working with industry to close down the vulnerabilities that fraudsters exploit and ensure members of the public have the information they need to spot a scam and stand up to fraudsters. This is a shared endeavour between Government, law enforcement and the private sector. It is vital we ensure that disabled and vulnerable customers are included in this effort, but there are no additional requirements on a bank to check for irregularities or fraudulent activity if a customer is disabled or vulnerable.
UK banks’ and building societies’ treatment of their customers is governed by the Financial Conduct Authority (FCA) in its Principles for Businesses. This includes a general requirement for firms to provide a prompt, efficient and fair service to all of their customers.
The FCA’s Guidance for firms on the Fair Treatment of Vulnerable Customers also requires that firms should understand what harms their customers are likely to be vulnerable to and ensure that customers in vulnerable circumstances receive the same fair treatment and outcomes as other customers.
If a firm has doubts about a consumer’s ability to understand a product or service, suspects they do not have capacity to make decisions or that they are acting as a result of fraud or coercion, the firm should assess whether it should allow the consumer to proceed. It may be appropriate for firms to contact, or act on the instructions of, a family member, friend or other third party.
In addition, like all service providers, banks and building societies are bound under the Equality Act 2010 to make reasonable adjustments, where necessary, in the way they deliver their services. This may include allowing for a carer or deputy to act for the disabled person.