How to test letters for vulnerable customers
To test a letter for vulnerable customers, include readers who reflect the vulnerability characteristics in FCA guidance FG21/1 and read the results for each group separately instead of relying on the average. Dutified's panel includes the vulnerable groups in FG21/1 and reports who struggled as well as how many.
What FG21/1 describes
FG21/1 sets out four drivers that can increase the risk of vulnerability, which are health, life events, resilience and capability. A letter that works for most readers can still fail a customer who is dealing with a health condition, a bereavement, money worries or low confidence with financial terms.
A practical approach
- Name the groups that matter for this letter. Decide which vulnerable groups are most likely to receive the letter and what each of them would need to understand from it.
- Test those groups alongside the wider population. A panel that covers your customer profile and the wider UK public lets you compare how each group responded to the same words.
- Look at who struggled before you look at the average. The groups that struggled show you which sentences to change first.
- Retest with the same panel. Running the changed letter past the same readers shows whether the change helped the groups that struggled.
How Dutified helps
Dutified tests letters, emails, web pages, app screens, ads, statements and call scripts on AI-modelled customers, so you can test a communication before it is sent without sharing real customer data. No customer data ever enters Dutified.
Where to look at the FCA
FG21/1 is the FCA's guidance on the fair treatment of vulnerable customers and FG22/5 covers the Consumer Duty, which asks firms to consider the needs of customers with characteristics of vulnerability. Read both for the exact wording.
- FG21/1, FCA guidance on the fair treatment of vulnerable customers
- FG22/5, FCA guidance on the Consumer Duty
- PRIN 2A.5, the consumer understanding outcome
- Consumer understanding: good practice and areas for improvement (FCA)
Questions and answers
What are the drivers of vulnerability in FG21/1?
FG21/1 describes four drivers that can increase the risk of vulnerability: health, life events, resilience and capability. A customer can be affected by more than one at the same time.
How do I find out which customers struggle with a letter?
Test the letter on readers who reflect each group and read the results group by group before you look at the average. The groups with the lowest understanding show you which sentences to change first.
Does testing for vulnerable customers need their personal data?
Dutified does not need it. No customer data ever enters Dutified, because its panel is modelled on a customer profile and the wider UK public, including the vulnerable groups in FG21/1.
Related guides
- How to test Consumer Duty communications
- Testing financial promotions with customers
- Consumer Duty communications glossary
Dutified gives feedback and does not give legal or compliance advice. It reports how modelled readers responded, and every decision stays with your firm.
To test your own communications with Dutified, join the waitlist or read how it works.