Consumer Duty is not only about policies, disclosures, and annual reviews. It is also about whether a firm genuinely understands the people it serves.
Consumer Duty is not only about policies, disclosures, and annual reviews. It is also about whether a firm genuinely understands the people it serves.
That understanding depends on information. Not just portfolio values or contact details, but the client’s circumstances, needs, family context, vulnerabilities, objectives, support requirements, and the changes that happen between formal review points.
When client information is static, evidence becomes thin. When the client record is alive, evidence becomes more useful.
Traditional records often capture a client at a point in time:
That snapshot matters. But clients do not stay still.
Between reviews, a client may retire, inherit, lose a spouse, become a carer, experience illness, change employment, move home, take on debt, support adult children, or become less confident managing financial information.
If the firm only updates the file once a year, important context may be missed.
The FCA’s Consumer Duty requires firms to act to deliver good outcomes for retail customers, with expectations shaped around areas including consumer understanding and consumer support (FCA). The FCA has also published guidance for firms on the fair treatment of vulnerable customers, highlighting the need to understand customer needs and make sure vulnerable customers are treated fairly (FCA).
In practice, this creates a simple question: how does the firm know what it needs to know?
A living client record helps answer that question.
A living client record is not just a bigger database. It is a more current and contextual picture.
It may help show:
This does not replace professional judgement. It gives advisers better context for applying it.
Consumer Duty evidence should not become a box-ticking exercise. A form can show that a question was asked. It may not show whether the answer still reflects the client’s life.
Better evidence may include:
The point is not more data for its own sake. The point is more relevant information at the moment it affects client outcomes.
Vulnerability can be temporary, permanent, visible, hidden, financial, emotional, health-related, or situational. A client may not identify themselves as vulnerable. They may not know what to disclose. They may not disclose it during an annual review.
Firms need ways to notice context:
The FCA describes a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care (FCA finalised guidance PDF).
That definition makes context critical.
Firms may want better records, but clients need a reason to keep information current.
A living record works best when it helps the client directly. If clients can organise documents, accounts, policies, property, wishes, trusted contacts, and family information in one place, they gain a personal benefit beyond the firm’s compliance or operational need.
That makes the record more likely to stay useful.
Lyfeguard helps clients build a permissioned record of important information and choose what to share with their adviser. For firms, that creates richer client context around documents, finances, family, vulnerabilities, life events, estate planning, and support needs.
Consumer Duty evidence becomes stronger when the client picture is not frozen in time.
