Vulnerability & Consumer Duty Advisory

Vulnerability is a spectrum. Most firms only catch the extremes.

I help banks, lenders and building societies meet the FCA's expectations on vulnerable customers — by training the people who actually have the conversations, and closing the gap between a sound policy and what happens at the front line.

Book an intro call See how I help
CopingShowing signsIn harm's way

Any customer can move along this line — through illness, bereavement, a life event, or low financial resilience. The job isn't to label people. It's to notice the slide before it becomes harm.

The gap

The regulator has already told firms where they're falling short.

In March 2025 the FCA published its review of how firms treat customers in vulnerable circumstances. The headline: good policies, but a persistent gap between policy and practice — and worse outcomes for the people least able to absorb them.

44%
of vulnerable customers reported a negative experience with their provider — against 33% of everyone else.
FCA review · 2025 ↗
£17m+
in fines to two retail banks in 2024 over the treatment of customers in financial difficulty.
FCA enforcement · 2024 ↗
7 banks
examined on power-of-attorney and bereavement journeys — where rigid processes repeatedly failed distressed customers.
FCA multi-firm work ↗
What I do

Three ways to close the gap.

Practical, evidence-anchored work that maps directly onto FG21/1 and the FCA's 2025 good-practice findings.

01 / Training

Frontline workshops

Half-day sessions that turn policy into confident practice for the staff who take the calls.

  • Spotting vulnerability when it isn't disclosed
  • Power of attorney & bereavement conversations
  • Recognising and responding to financial abuse
  • Mental capacity in plain, usable terms
02 / Review

Policy & process gap analysis

A clear-eyed review of where your journeys fail vulnerable customers, benchmarked to the regulator's own examples.

  • Gap analysis against FCA good practice
  • PoA & bereavement journey redesign
  • Outcomes-monitoring that stands up to scrutiny
  • Board-ready findings and actions
03 / Advisory

Complex case support

A safeguarding specialist on call for the cases your team can't resolve alone.

  • Capacity questions under the Mental Capacity Act
  • Financial-abuse escalation and decision-making
  • Coordinating with social services and safeguarding leads
  • Retained or per-case
Why Threshold

Compliance consultants know the rules. I know the person on the other end of the call.

Most vulnerability training is written by people who've never made a capacity judgement or sat with someone disclosing abuse. I have — across multiple London boroughs, every week. That clinical authority is what makes the training land and the advice hold up.

Qualified social workerFrontline adult safeguarding across London boroughs
Mental Capacity Act specialistCapacity assessment and best-interests decision-making
Neurodevelopmental assessmentADOS-2 and DSM-5 certified
LLB, Business LawFluent in regulatory obligation, duty of care and liability
Multi-agency coordinationWorking across health, social care and safeguarding systems
How it works

Start small. Prove the value. Then embed it.

STEP 01

Pilot

One workshop or a focused journey review, at a fixed fee — so you see the value before you commit to more.

STEP 02

Embed

Roll training across teams and redesign the specific journeys that are failing vulnerable customers today.

STEP 03

Retain

Quarterly reviews, refreshers and outcomes-monitoring support — the ongoing evidence the FCA expects to see.

Get started

Reducing the risk starts with a conversation.

Tell me where your vulnerable-customer outcomes are under pressure, and I'll tell you honestly whether I can help — and what it would take.

Book an intro call