Embracing Neurodiversity: Consumer Duty regulation and financial firms’ responsibilities.
by Tasha Roger
Amidst the evolving landscape of the UK's financial advisory sector, independent Financial Advisor (IFA) firms are steering through a maze of regulations enforced by the Financial Conduct Authority (FCA), all aimed at ensuring fairness and transparency for every client. Leading this regulatory charge is the Consumer Duty regulation, unveiled in July 2021—a beacon of change promising a new era of client-centric care.
This regulation heralds a pivotal shift, especially for neurodiverse consumers. It's not just about meeting basic standards; it's about reshaping the financial advisory world to proactively improve outcomes and uplift the level of care for all clients, recognizing and catering to the unique needs of the neurodiverse. This regulation is more than a mandate; it's a mission to ensure every client's best interests truly come first.
An important area of the regulation is assessing client vulnerability, identifying and appropriately supporting vulnerable consumers, ensuring they are not exploited and are receiving fair treatment.
The FCA identifies vulnerable clients that fall into any of the following categories – with the caveat that all consumers are at risk of becoming vulnerable:
Poor Health – Cognitive Impairment.
Life Events – Such as new caring responsibilities, death, divorce.
Low Resilience to cope with financial or emotional shocks.
Low Capability – such as literacy or numeracy skills.
To uphold the principles of the Consumer Duty, IFA firms must look at how they can implement adjustments for vulnerable consumers and assess their accessibility, equity, and inclusion practices.
Considerations for Neurodivergent Consumers
If we look at the categories above and consider the diverse range of neurological conditions such as autism, ADHD, dyslexia, and dyspraxia; it could be deemed that neurodivergent consumers are captured within the vulnerability criteria of which IFA firms, in line with the Consumer Duty regulation, must undertake strategies to provide suitable adjustments for neurodivergent consumers.
Neurodiversity encompasses a range of neurological differences that influence how individuals perceive, experience, and interact with the world. Neurodivergent clients may exhibit varying communication styles, information-processing preferences, and sensitivities to sensory stimuli.
Reasonable adjustments that could be made to support neurodivergent consumers include but are not limited to:
1. Tailored Communication Channels: Offer multiple communication channels such as email, telephone calls, video conferencing, or in-person meetings.
2. Clear and Simplified Information: Present financial information in clear, concise language, avoiding jargon and complex terminology. Visual aids, diagrams, or interactive tools can enhance understanding for clients with dyslexia, ADHD, and/or other cognitive differences.
3. Flexible Appointment Scheduling: Recognise that neurodivergent clients may benefit from flexible appointment scheduling to accommodate their routines or sensory sensitivities. Providing advance notice of changes, courtesy appointment reminders the day before and allowing ample time for appointments can alleviate stress and promote a positive consumer experience.
4. Empathetic Listening and Patience: Practice active listening and demonstrate empathy towards consumers’ unique perspectives and concerns. Neurodivergent individuals may require additional time to process information or articulate their thoughts effectively. Patience and understanding are essential for building trust and rapport.
5. Accessible Documentation and Technology: Ensure that all written materials, including contracts, disclosures, and online platforms, are accessible and compliant with accessibility standards. Consider offering assistive technologies or alternative formats for clients who may have difficulty accessing traditional print materials.
6. Training and Awareness: Provide ongoing training and education for staff members to raise awareness of neurodiversity and best practices for serving neurodivergent consumers. Foster a culture of inclusion and diversity within the firm to support consumers from all backgrounds.
Whilst there is the understanding that not every neurodivergent consumer would classify themselves as vulnerable, it is important to acknowledge that firms should be eager to understand individual needs to agree on mutual adjustments, with the goal of everyone onboarding with the firm experiencing an excellent consumer experience.
If you’re ready to embark on this journey towards greater inclusivity and accessibility, we encourage you to reach out to the Welcome Brain team. Together, we can work towards building a more inclusive financial advisory experience for all.
Tasha Roger
About the author
Boasting 7 years of invaluable experience within the financial sector, She has carved out a niche as a dedicated consultant specialising in supporting Independent Financial Advisor (IFA) firms.
She has a deep commitment to fostering a neurodiverse inclusive culture. With a unique perspective informed by AuDHD, she champions for an environment that celebrates diversity across the employee and finance client experience.
