On 4 May 2020, the FCA updated its web page concerning information for firms on Coronavirus. The FCA has added a new section “Accessing restricted savings”.
The FCA states that data from the Financial Lives survey suggests that several million people may have restricted savings as their only form of savings, If they cannot access their savings, they may be unable to cover essential outgoings, or need to take on additional debt instead. When customers contact firms asking to withdraw funds from these accounts the FCA would expect firms to:
- pay due regard to the interests of their customers and treat them fairly (see Principle 6 and BCOBS 5.1);
- communicate in a way that is clear, fair and not misleading (see Principle 7 and BCOBS 2.2); and
- consider the needs of vulnerable customers in their actions or communications (see Principles 6 and 7).
The FCA adds that meeting these obligations does not require firms to offer access to all customers, or to offer unlimited access to funds in a restricted access account. Firms are free to form a judgment on a case by case basis, balancing their customers’ needs with their own obligations, including managing their prudential risk. However, in doing so, firms should also be aware that for some people the impact of Coronavirus is likely to exacerbate the personal circumstances that can cause vulnerability. In deciding how to respond to customers in a way that is consistent with the above obligations, firms should consider the customer’s vulnerabilities and the impact that an inability to access funds would have.