A new Consumer Duty: what is your organisation doing?

London city cover

For the first time, financial services providers will now have to monitor and evaluate the outcomes of all retail customers whatever their personal circumstances. What are you doing at your organisation to respond?

The countdown has now started as the Financial Conduct Authority’s (FCA) New Consumer Duty comes into force on 31st July 2023 for all new and existing products. The outcomes-based rules raise the level of care that retail customers should expect to receive from financial institutions in a bid to reduce financial harm and improve financial inclusion.

The rules require firms to consider the needs, characteristics and objectives of their customers – including those with characteristics of vulnerability – and how they behave, at every stage of the customer journey. As well as acting to deliver good customer outcomes, firms will need to understand and evidence whether those outcomes are being met.

PS22/9: A new Consumer Duty Financial Conduct Authority 2022.

These rules come into being at a time when households and businesses face high inflation and the prospect of economic contraction. The UK Consumer Prices Index (CPI) rose by 9.4% in the 12 months to June 2022, up from 9.1% in May. Meanwhile, wage growth of 5.3% is in stark contrast to the year on year inflation rates of 53.5% for electricity and 95.5% for gas in April 2022.

Financial vulnerability can affect us all

The FCA defines financial vulnerability as a group of characteristics that apply to customers who, due to their circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Financial vulnerability runs on a continuum, and everyone is at risk of becoming financially vulnerable at different points throughout the life-course. The FCA surveyed over 12,000 UK adults and found that 53% of them show one or more characteristics of financial vulnerability. Between March and October 2020, the number of adults displaying characteristics of vulnerability increased by 3.7 million, reaching 27.7 million.

Too little, too late? Or a call to action?

In the face of a crisis of financial resilience, it is hoped that these rules will prevent future financial harm to individuals because financial institutions will now be required to take appropriate steps to protect their customers. Greater care will now have to be taken in the design of any financial product or service sold, the price and value of those services, customer understanding of the product as well as the support provided.

However, some may argue that these rules are ‘too little too late’ as millions are already struggling with the cost of living crisis. The Office for National Statistics recorded that 91% of adults in Great Britain reported an increase in their cost of living between June and July 2022. In its March 2022 forecasts, the Office for Budget Responsibility (OBR) expected household incomes after tax and adjusted for inflation to start falling in Q2 2022 and to not recover until Q3 2024.

Proactive monitoring, evaluating, and reporting vs reactive remedial actions

Financial institutions must act in good faith, take all reasonable steps to avoid foreseeable harm to consumers and take all reasonable steps to enable consumers to pursue their financial objectives. For the first time, financial services providers will now have to monitor and evaluate the outcomes of all retail customers whatever their personal circumstances. So for example, the impact of a financial product on a single-parent household with low financial resilience would be compared with more resilient customers to track the rate of financial harm in both groups. 

The aim is to narrow the gap between customers with characteristics of financial vulnerability and those without through higher standards of care. The exact way this is done will vary depending on the process adopted by the financial institution. However, it will no longer be good enough to simply say “we’ve got a process for that” but this process should make a meaningful difference to the experience of the consumer, and be continuously monitored and reported to the Board. 

Knowledge and understanding of vulnerability is low, but ignorance is no defence. Help is at hand.

The New Consumer Duty is far-reaching and its addition to the FCA handbook for regulated firms is a step in the right direction. Enforcement of the rules for new and existing products is due in 12 months and 24 months for products closed to new customers. The lack of fixed financial penalties for misconduct does make these rules less stringent than what some were hoping (or feared) but it is a good start. However, enforcement must be consistent and may prove to be a test for the regulator and financial institutions as the understanding of the concept of financial vulnerability is still low and significant training across all departments will be required to effectively implement the New Consumer Duty. 

As firms review their services to comply with the rules, there will be some level of burden on organisations to implement additional internal monitoring and evaluation processes that are appropriate and meaningful enough that effective action can be taken by management teams. 

This is why my team and I have developed a masterclass in conjunction with The London Institute of Banking and Finance (LIBF) in Financial Vulnerability that helps anyone working in financial services understand what is required of them in implementing the New Consumer Duty and the Fair treatment of Vulnerable Customers. 

In addition to improving understanding of the concepts of financial vulnerability, the masterclass will also introduce the neuroscience of financial decision-making and provide frameworks designed to help attendees comply with the FCA guidance in their day-to-day practice. The FCA has made the importance of this very clear and everyone working in financial services must improve standards and customer vulnerability will no longer be a customer service issue.t is now everyone’s responsibility.

Apply to Attend the Financial Vulnerability Masterclass at LIBF


The Financial Vulnerability Masterclass consists of three interactive workshops, which will take place over three days. Each workshop will last between 2.5 and 3 hours and will be hosted through Zoom.

The first masterclass will begin on Wednesday 7 September 2022 at 3pm and costs £1,250. If you wish to make a group booking of five people or more, that price drops to £950 per person.

Masterclass programme schedule:

  • Wednesday 7th September at 3pm
  • Wednesday 14th September at 3pm
  • Wednesday 21st September at 3pm

You’ll learn through a mix of group work, case studies and practical exercises. As you absorb your new knowledge, you’ll be encouraged to consider how it might apply to your own work and organisation. Our trainers have industry, as well as academic, experience to help you gain the practical skills you need, along with a deeper conceptual understanding.

If you wish to count this masterclass towards your continuous professional development (CPD), it’s worth 9 CPD points.

Fears of a spike in vulnerability on the anniversary of the FCA guidance on protecting vulnerable customers 

This week marks a year since the Financial Conduct Authority (FCA) issued guidance to financial institutions for the fair treatment of vulnerable customers. The aim of the guidance is to encourage banks and building societies to better understand the needs of vulnerable customers so that they can better serve them.

Ahead of the anniversary, we conducted research for an up to date picture of how prevalent financial fraud is in the UK, and the results were very concerning. Of the 2,000 people surveyed, 22% said they have been tricked out of money at some point during their lives – that’s more than 1 in 5 of us. 

On average, they lost £1,002 each, and this rises to £1,523 for people who have a carer – suggesting a relationship between vulnerability and a higher susceptibility to financial fraud. Dispelling the myth that only older people are targeted, the age group that lost the most money was those aged 25-34 who were duped out of £1,355. Losses of£10,000 or greater were experienced by 3% of all respondents – a life changing sum for most people.

The public health need for coronavirus restrictions accelerated the transition to digital across most industries – but with it came an increase in the number of opportunistic scammers, especially as many people were using online banking and shopping services for the first time. Around 41% of the people we surveyed said they had been targeted by a scam since March 2020.

The mental, physical and financial hardships endured during the pandemic, and the cost of living crisis amplified by recent geopolitical risks in Europe have hit living standards. The impact of these events will continue to take their toll with the number of people experiencing financial vulnerability likely to increase. Two in five (21%) of our respondents self-identified as financially vulnerable and 17% said they don’t think through financial decisions as well as they did before the pandemic.

Despite the FCA guidance, financial vulnerability has increased, and under current circumstances, it looks set to rise further. The need to tackle financial vulnerability is more pressing now than ever, but to truly achieve this, we need a multisector, multidisciplinary and multi skills approach. Industries, including finance, technology and healthcare, need to come together to improve the way we detect the characteristics and drivers of vulnerability so that we financial institutions are equipped to intervene before it’s too late. 

Fears of a Spike in Financially Vulnerable Brits on ‘Divorce Day’

  • A fifth (21%) of Brits left financially vulnerable due to the demise of a relationship
  • 16% of Brits trapped in unhappy relationships as they can’t afford to live alone
  • Almost 1 in 10 (9%) say they would leave their partner today if they could afford it
  • Fears of an increase in financial vulnerability on national ‘Divorce Day’ when law firms see a spike in divorce filings as pandemic and higher living costs take their toll
wedding rings in the rain

London, 10 January: As we approach what is unofficially known as ‘Divorce Day’ – the first working Monday following the Christmas period when law firms typically see a spike in divorce filings – new research[1] warns of a potential spike in financial vulnerability.

Research commissioned by Kalgera, an AI powered platform designed to help banks and financial institutions identify and protect vulnerable customers from financial harm, found that more than a fifth (21%) of Brits have been left financially vulnerable following the end of a relationship.

The impact of the ongoing pandemic to health and wellbeing, coupled with the challenges of homeschooling have intensified pressures for families and couples since March 2020. Added to this, fears over job security against rising living costs have compounded money worries for many, putting strain on relationships.

The research suggests we can expect to see more divorce filings on Monday as 13% of people say they are in an unhappy relationship while 7% plan to leave their partner within the next six months.

Alongside the emotional heartache, the effects of a divorce can have a devastating impact on personal finances. Almost a fifth (18%) of Brits say they have found themselves in a financially precarious situation, including bankruptcy, following a breakup while 16% say a divorce has left them with debt that will take more than six months to clear.

Kalgera warns this could lead to a rise in the number of people experiencing financial vulnerability, which has already increased since the start of the pandemic[2], and therefore more susceptible to falling victim to increasing sophisticated scams designed by criminals to defraud people out of money. 

Founder of Kalgera, Dr Dexter Penn, said: “The breakdown of a long-term relationship is a major life event, not just emotionally but also financially. We have seen a concerning increase in the number of people displaying characteristics of financial vulnerability as a result of the pandemic. The financial shock of the loss of a partner is likely to exacerbate the situation. Our research suggests we may see a high number of breakups and divorce proceedings as the strain of the last two years takes its toll.

“The psychological stress of heartbreak and financial worries negatively impacts concentration and mental health. The combination makes us all more vulnerable and sadly, more susceptible to convincing and opportunistic fraudsters. During these challenging times, it’s important to look after ourselves and our loved ones, remain vigilant and seek help and raise concerns if something doesn’t seem right.”   

The turmoil of a breakup can have a profound effect on day-to-day life for many people. Almost a quarter (23%) have suffered mental health issues as a result of a relationship ending and 19% say they are less able to cope with everyday life as well as they could before. These factors can significantly impair a person’s judgements, and potentially deplete their bank balance if lured by a fraudster.

On the other hand, the research also suggests some people are trapped in unhappy unions due to money worries. ​​16% of Brits claim they cannot leave their current relationship as they do not have enough money to live by themselves and almost one in 10 (9%) say they would leave their partner today if they could afford it while 8% say they got into a relationship because they could no longer afford to be alone.

Marcie Shaoul, Director of The Co-Parent Way said: “When divorcing or separating from a partner, it is easy and common to be caught up in high levels of emotion. When we feel like this it can be really hard to make clear decisions about your welfare, your financial welfare, or the welfare of your children. Today’s figures showing the increase in people divorcing are worrying, not least because more people may be left in a financially and emotionally vulnerable position. Getting the right support during divorce is essential for wellbeing and resilience as well as our financial security, and the continued wellbeing of children.”

Since the beginning of the Pandemic, nearly one in 10 (9%) Brits have completed divorce proceedings and a further 5% are currently going through divorce proceedings.

[1] Commissioned by Kalgera, conducted by Opinium Research with an online sample of 2,001 nationally representative UK adults between 30 Dec 21 and 4 Jan 22.

[2] FCA Financial Lives 2020 survey: impact of coronavirus

About Kalgera

Kalgera was born from a desire to better protect the financially vulnerable. It is designed to have the greatest impact for the widest possible community. The company does this by enabling banks and other financial institutions to identify and protect vulnerable customers from financial harm through its Artificial Intelligence platform. The platform uses cutting-edge cognitive neuroscience research to analyse financial behaviour captured in transaction data. This is processed with ‘deep tech’ data science to interpret financial behaviour. This proprietary process automatically self-improves using AI.

The RegTech was founded by Chief Executive, Dr Dexter Penn, who is also a clinician at the UCL Dementia Research Centre. The company was in the elite cohort on the National Cyber Security Accelerator Programme by Wayra as well as taking part in the FCA’s Digital Sandbox Pilot.

For press enquiries or for interview requests please contact:

Susan Hayes susan@impactandinfluence.global +44 (0)77699 71990

Rishi Bhattacharya rishi@impactandinfluence.global +44 (0) 7767 654 070

About The Co-Parent Way

The Co-Parent Way is the UK’s only Co-Parent Coaching Practice. Its director, Marcie Shaoul, is a thought leader in co-parenting and is responsible for developing a unique coaching methodology that enables parents to get to a place where they can co-parent together effectively after separation. It provides coaching specifically for couples or individuals who are separating and who have children. www.thecoparentway.com


Photo credit:



Why Diversity is Essential in Startup Teams

Diversity at Kalgera

The positivity surrounding this inclusion contributes significantly to team morale when we are working tirelessly to create a solution that will be valued by all its users. Perhaps more importantly, Kalgera is able to extend its inclusivity ethos to its users, where the team and product seek to understand and act on all its user concerns regardless of any differences.

There is a wealth of research highlighting the correlation between high diversity and greater innovation, and Kalgera has created a culture that celebrates and embraces diversity. 

For example, did you know that companies that are diverse are 35% more likely to gain higher financial returns (McKinsey, 2015)? The Kalgera team is very diverse, so we’re already starting out with greater odds of our people and product succeeding and thriving.

diversity - image of diverse faces


There are a variety of dimensions associated with diversity, including traits such as age, gender, philosophical perspective, values, ethnicity and economic status.

When we talk about managing diversity, we are referring to embracing a mosaic of people who bring a variety of perspectives, styles, values, backgrounds, and beliefs to the team and its vision, with each of these contributions carrying equal value.

When executed cohesively and positively, managing diversity is the art of thinking independently together. This approach can only enhance the progress towards a united vision.


Diversity implies a seamless inclusion in a team that respects and accepts each individual despite their differences. Working in a diverse team opens a space to reflect and encourage members to be more aware and understanding of others background, perspectives and values.

It provides each person with an opportunity to wonder more about the world, as well as different people and cultures while allowing the team to identify and work to fill in gaps in personal knowledge, culture and experiences.

An individual’s outlook towards life grows and those working in diverse teams tend to develop a sense of responsibility to create something meaningful.


  1. Strength lies in differences and not similarities and diversity is now an accepted norm of socially responsibility.
  2. It ensures the dynamic of the business more accurately reflects the outside world, facilitating the creation of solutions that are viable.
  3. Diversity also ensures the technologies businesses create are developed to meet everyone’s needs and does not exclude vulnerable or minority groups in our society.
  4. Multiple perspectives contributed to a project encourage varied and creative thinking during team and stakeholder discussions.
  5. As there are a variety of options, the solutions are assessed more critically and members are empowered to be more thorough and creative in their arguments, leading to the creation of more innovative solutions.
  6. The variety and consequent discussions lead to a better decision-making process as all suggestions are assessed with more but equal scrutiny. Ultimately, diversity contributes significantly to the creation of a better quality product that considers the needs of the wide range of its different users.

Financial Inclusion: Can we all be a part of a FinTech Future?

Considering we are currently living in a world in which people are living for longer than ever before, technologists have a duty to adapt fintech to suit the needs of older adults and contribute significantly to overall financial inclusion.

According to the Financial Lives Survey carried out by the UK Financial Conduct Authority (FCA) in 2017, online is rapidly becoming the dominant channel for basic financial activities. Nevertheless, the proportion of online banking activity and usage of contactless payments sharply decreases as people get older.

For example, 75% of adults have checked their balance online in the last 12 months, but this number drops to just 25% for those aged 85+. Although the strong association between technology and younger adults is part of the reason for the decline, fintech might also not be addressing issues that older people are facing.

Financial Inclusion - Senior woman working at cafe using her laptop and talking on mobile phone
Does FinTech address the issues faced by older people?

 Similar to younger populations, older ones are equally diverse and have individual needs, which fintech companies can consider and cater to. Sue Lewis, an author of the FCAs Financial Services Consumer Panel report, states that it is:

“…imperative that the industry explains products simply, and takes account of the particular needs of older consumers, which might include, for example, using larger font sizes, or more interactive contact through face-to-face meetings or online video chats, like Skype”


“…imperative that the industry explains products simply, and takes account of the particular needs of older consumers, which might include, for example, using larger font sizes, or more interactive contact through face-to-face meetings or online video chats, like Skype”.

The report also describes how there are already innovations in place helping customers, such as the introduction of biometrics (finger print recognition), so customers no longer need to remember ‘memorable words’.

Another helpful approach involves using video or graphical content, which makes information clear and easy to understand. This approach is currently being taken in the USA, where OceanFirst bank placed video teller machines in pension homes allowing residents to speak to someone from their bank at the press of a button. Bank cards are not needed for these machines and they are able to do almost everything you can do at a normal bank branch.

Another idea from Tom Kamber, who is director of Older Adults Technology Services, is the project ‘Ready, Set, Bank’ with Capital One. This project aims to make online banking easier by creating short online video courses.

In the UK, Kalgera has a social aim of safeguarding the financial wellness of vulnerable people. Half of UK adults show signs of financial vulnerability and personally lost £1.2 billion to fraud and scams in 2018 alone with 5 million older people being targeted each year by fraudsters.

Kalgera uses machine learning to analyse financial transactions to detect subtle signs of vulnerability and the risk of falling victim to scams. Kalgera also helps by securely facilitating shared view-only access to financial transactions with trusted family and friends so they too can be alerted without compromising their bank details and without the ability to move money. This means that an older person can quickly get advice from someone they already know and trust if something doesn’t seem right without giving up control of their finances.

The perspective that older people do not want to learn about or use technology is incorrect and potentially leads to digital and financial exclusion, especially given technology can support independent living if it is adapted appropriately. Kalgera demonstrates that being tech savvy has no expiry date, and entreat quite the opposite as the company’s name means ‘good old age’ in Ancient Greek. Ultimately, there is everything to be gained in providing better safeguards to protect the finances of those most vulnerable people as we all benefit in the end.

How data portability can improve our lives

Two and a half quintillion bytes or 2,500,000,000,000,000,000 bytes of data are generated every single day. The majority of all data in existence was generated within the past few years and is created collectively by individuals, governments and businesses. Data is knowledge but is meaningless until it is processed and interpreted in context at which point it becomes information on which a judgement or decision can be taken. Data is now considered a key ingredient for current business revenue models, a yardstick by which service success is measured. Entities that do not use data effectively and appropriately increasingly risk becoming extinct.

Large library used as an visual representation of data
Data is knowledge but is meaningless until it is processed and interpreted in context at which point it becomes information on which a judgement or decision can be taken.

The protection of personal data, consumers and competition in markets is increasingly important for policy makers and competition authorities. Open Banking regulation from the UK Competition and Markets Authority (CMA) and General Data Protection Regulation (GDPR) by the European Union are prime examples of this shift in importance. 

The right to data portability was introduced in the GDPR and enacted in the Data Protection Act 2018. This gives individuals the right to not only obtain a copy of their personal data but also to instruct organisations to transfer these data to third parties. These data must be machine readable and in a common format which renders them useful. This appears to be fairly innocuous, however, represents a radical step in delivering greater autonomy to consumers. This also raises several important questions related to data harmonisation, market effects, organisational processes, and crucially consumer benefit. This article is the first in a series that will examine these issues and the potential impact on business and consumers.

Financial services presents a compelling use case for data given the fundamental nature of banking and finance on our daily lives. The use of artificial intelligence (AI) has the potential to transform the processes, products and services of the industry. For example, AI can analyse millions of data points to detect fraudulent transactions that tend to go unnoticed by humans while simultaneously actively learning and calibrating to new potential threats. Simple risk factor checklists are no longer enough given the fact that global fraud losses were £3.2 trillion in 2018. 

Open Banking is a great opportunity for financial institutions to leverage the masses and masses of consumer data held to generate greater value and new potential revenue streams. However, this is no mean feat given the fact that these data exist in a multitude of formats on difficult to maintain legacy systems installed decades ago and written in code developed in the 1950s or worse, on paper. Unstructured (i.e. not pre-processed) or inconsistently structured streams of financial data poses a risk to the quality of the resultant algorithms. This risk can be compounded by the loss of corporate memory as coders familiar with legacy systems retire. Data harmonisation with the aim of making the structure of all financial data easily analysable by machines will be essential to the removal of current bottlenecks. Cooperation between stakeholders and market actors will be required to achieve this and a diverse workforce with a variety of skills will be required. 

Mobile screen showing someone using an app

The digitalisation of consumer banking has long been an uphill battle given the legacy of deregulation where the risk taking of securities trading lived in parallel with the culture of caution and conservatism of banking. The consumer trust lost as a result of the financial crisis a decade ago will require more than marketing savvy but a serious revision of the social contract between banks and consumers. 

Kalgera was developed to serve people typically overlooked and this presents a unique challenge. These groups can be difficult to reach, have variable personal circumstances and hold little trust in financial institutions. Multiple human factors were considered in the design process as well as differences in personal relationships with money. For example, older people tend to see money as something to share which enriches the lives of those around them rather than a means of achieving individualistic goals. Using data to better understand the true challenges of the consumer and go on to predict when and how they will require service to meet their challenges unlocks value to the individual and markets. Shifting to truly mission driven data powered services deployed in an ethical way can improve financial services and build social capital.

Further reading

Analytics Comes of Age, McKinsey Analytics, 2018.

The Financial Cost of Fraud 2018, Crowe, 2018.

Artificial Intelligence in Finance, Buchanan, Bonnie, 2019.

Mind your Mental Health

It has been an extremely challenging few weeks and many of us have struggled with the health and economic fallout of the lockdown and social distancing. The world has been irrevocably changed and we too must change with it by being more resilient.

Watch Dr Dexter Penn share a moving story from his family experience of mental health problems.

Some of us have taken to exercising with Joe Wicks every morning, some of us have taken refuge in the kitchen, the garden or have thrown ourselves into long overdue DIY projects. Unfortunately, some of us are not coping and we all need to be vigilant of the signs of distress in our friends and family.

This is particularly important for the Black community as Black people are more likely to develop a mental health condition like psychosis but Black people in Britain are least likely to access treatment.

If you are finding it particularly difficult please talk, we are here to listen.

Learn more

Lubian, K., Weich, S., Stansfeld, S., Bebbington, P., Brugha, T., Spiers, N. … & Cooper, C. (2016). Chapter 3: Mental health treatment and services. In S. McManus, P. Bebbington, R. Jenkins, & T. Brugha (Eds.), Mental health and wellbeing in England: Adult Psychiatric Morbidity Survey 2014. Leeds: NHS Digital.

The Mental Health Foundation (2020). Black, Asian and Minority Ethnic (BAME) communities. Available: Online

Qassem, T., Bebbington, P., Spiers, N., McManus, S., Jenkins, R., & Dean, S. (2015). Prevalence of psychosis in black ethnic minorities in Britain: Analysis based on three national surveys. Social Psychiatry and Psychiatric Epidemiology, 50(7), 1057–1064.