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How is vulnerable customer identification faring in the consumer finance sector?

Author: Jonathan Barrett, CEO of Comentis

Consumer Duty, the Financial Conduct Authority’s (FCA) initiative to protect customers including those who are vulnerable, has been in place for a little over six months now. Jonathan Barrett, CEO of Comentis evaluates how consumer finance firms are coping with their vulnerability assessments and what the regulator will want to see next.

We’re six months in from the FCA’s Consumer Duty regulations coming into force, and in general, we’re seeing a mixed bag in terms of how firms are faring with their vulnerability assessments. Some firms are doing well and making traction, whilst others seem to be struggling somewhat.

Perhaps most worryingly of all, there still seem to be a small number of firms who feel that they don’t need to change their ways of working in line with their Consumer Duty obligations. Some, for instance, might think that being smaller means they’re safe from the Duty or that it doesn’t impact their sector specifically. But whilst it may be true that the FCA will focus most of its attention on the largest players, the regulator has been very clear that there will be no exceptions made, and likewise that no industry is exempt.

Consumer Duty – the requirement to protect customers, including those who are vulnerable – has a fundamental impact on all firms providing regulated financial products or services to consumers. It requires firms to act to deliver good outcomes for their retail customers and ultimately keep them safe.

Consumer Duty will have a fundamental impact on all retail consumer creditors offering a finance plan. Regardless of whether the purchase on credit is big or small, from buying a car to a pair of glasses, all firms must ensure they can identify each and every instance of vulnerability and provide ‘good outcomes’ for their customers and the appropriate support.

The impact of this on the UK consumer finance market is huge. Take the motor finance market for example, the rate at which cars are being bought on finance shows no sign of slowing, with the average sum borrowed in the UK for a new vehicle shooting up from £11,964 to £25,039 in the space of just 13 years.

With such large amounts being spent, and with the cost-of-living crisis putting household budgets under significant pressure, it’s vitally important that potential customers are accurately assessed for any risk of vulnerability before they’re offered any form of finance arrangement.

But what is vulnerability exactly?

The FCA defines vulnerability as:

“Customers who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Firms should think about vulnerability as a spectrum of risk. All customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to 4 key drivers.

• Health: health conditions or illnesses that affect ability to carry out day-to-day tasks.

• Life events: life events such as bereavement, job loss or relationship breakdown.

• Resilience: low ability to withstand financial or emotional shocks.

• Capability: low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy, or digital skills.”

Vulnerability could stem from illness, divorce or low resilience – triggers that have all been defined by the FCA – as well as from a threat to someone’s income or their suitability for credit. It’s the emotional, mental and cognitive response to these circumstances that leaves someone vulnerable, and as such, they must all be correctly identified.

Undoubtedly the identification process is complex, even for a trained clinician, but for sales professionals who lack an in-depth knowledge of the nature of vulnerability, identifying at-risk customers will prove an incredibly difficult task without technological support.

The other thing to keep in mind is that this is not a once said and done thing. Time and again the regulator has made it clear that Consumer Duty is not a one-off exercise, reminding us all that firms will need to make sure they are continuously learning and improving.

Nisha Arora, Director of Cross Cutting Policy and Strategy at FCA:

“It’s something that needs to become part of who you are as a firm, your culture, and how you do business, running across your whole organisation from Board to front-line delivery, from product design to communications and customer support.”

To do this though, data is key.  

Those that are starting to make traction have started to build up hard data on vulnerability. Six months in, we believe that there’s a real opportunity for these firms to assess what they’ve gathered so far, take stock, and see if their target market assumptions are playing out as expected. And if any vulnerabilities have been identified, they could also look at how well that individual customer has actually been supported. With this knowledge, they can then determine whether their preparations were fit for purpose or if there are changes required and then develop from there. Of course, the FCA is not expecting a transformation overnight, but it is expecting organisations to build their banks of vulnerability data and learn and adapt based on this.


The best way to achieve this is with data and a systematic process for screening clients and appropriate accommodations for the needs of those at risk. By combining clinical expertise with hard data, these kinds of solutions can remove bias and subjectivity from the process, ensure consistency across a whole client base and reassure firms that their systems will adequately meet the scrutiny of regulatory requirements.

In the long run, this is a process that will benefit everyone. If you’re struggling, or if you know that you need to bring in additional expertise, don’t delay any further.

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How 5G and AI shaping the future of eHealth

Global Director for AI/ML Solutions, Mona Nia Tecnotree

The digital transformation of the healthcare industry continues to gain momentum. This shift can be attributed to the rapid advancement of widely applied technologies such as 5G networks, cloud computing, artificial intelligence (AI), and big data.

Moreover, integrating 5G networks with cloud-based healthcare platforms and AI is driving the emergence of intelligent eHealth technology, projected to reach $208 billion by 2030, according to recent reports. Recent research by Grand View Research emphasises that the synergy between 5G and AI is pivotal in transforming healthcare by enabling faster data exchange, reducing latency, and improving the reliability of health solutions. This collaboration aims to revolutionise the healthcare sector by facilitating hyper-personalisation, optimised care, enhanced sales and services, and streamlined operations. Leading venture firms actively invest in healthcare start-ups using AI, fostering a rapidly growing ecosystem of innovative advancements.

As AI and 5G continue to make waves through all industries, healthcare needs to adapt to changes quickly. However, with operational, security, and data privacy concerns, healthcare organisations remain wary. As such, they must analyse their current and future needs to understand how AI and 5G technologies can help fulfil them and establish a comprehensive plan to guarantee its efficient and secure implementation in their practices.

Recent research by the International Data Corporation (IDC) emphasises that the synergy between 5G and AI could potentially reduce operational costs by up to 20% and improve patient outcomes by enabling more accurate diagnostics and personalised treatments.

5G Integration in eHealth

5G technology stands at the forefront of healthcare reform with its superior data speed and dramatically reduced latency. Tailored to concurrently accommodate multiple connected devices such as sensors, wearables and medical equipment, 5G is truly indispensable in healthcare, allowing IoT devices to seamlessly transmit accurate data for healthcare providers.

It empowers healthcare professionals to handle large, high-definition files like clinical visuals, videos, and real-time patient insights. 5G’s capability for network slicing—dedicating specific network segments for certain uses—simplifies the management of such files. In addition, it optimises the performance of each application, thereby removing the strain on medical staff.

However, the implementation of 5G technology shouldn’t be oversimplified. It’s essential to analyse the potential risks and challenges thoroughly. A principal component to consider is regulatory cybersecurity and data privacy. Given that 5G networks are susceptible to cyber attacks, it falls upon healthcare providers to protect data such as patient information.

Organisations should also consider the financial implications of implementing 5G technology, as it involves a considerable investment in infrastructure and equipment. Therefore, they must balance the potential gains against the costs to ensure the viability of the investment.

Recent discussions at Mobile World Congress 2024 highlighted the critical role of regulatory frameworks in ensuring the secure deployment of 5G in healthcare. Experts advocated for robust cybersecurity measures and collaborative efforts between technology providers and healthcare institutions to mitigate potential risks.

Marrying 5G and AI for Improved eHealth Solutions

Despite the challenges, integrating 5G and AI will pave the way for unprecedented growth within the internal medical ecosystem, enhancing healthcare quality and patient results. For example, deploying data to carry out descriptive-predictive-prescriptive analytics and transmitting the acquired insights using 5G can drastically improve the user experience while helping make informed decisions. Such an approach can assist healthcare organisations in identifying promising healthcare use cases like remote patient monitoring, surgical robotics, and telemedicine.

Moreover, AI-facilitated hyper-personalisation, driven by the profusion of data accessible through 5G networks, can evaluate patient histories, genetic profiles, and lifestyle elements alongside real-time vitals to prescribe tailored advice and treatments. AI can also automate scheduling appointments, streamline supply chain management, and enhance transactions such as claims and prior authorisations. AI-powered chatbots and virtual assistants can deliver real-life support, while patient and customer service applications can provide an enriched experience through increased data accessibility.

AI can also streamline healthcare services by predicting and managing disease outbreaks. Supported by 5G’s capacity for real-time operability, AI systems can instantly analyse patient data, oversee bed availability, and notify medical personnel of potential complications—promoting efficient, effective care delivery.

Finally, AI-empowered fraud detection algorithms operating on 5G networks can analyse copious amounts of data in real time to detect suspicious activities and alert responsible security teams. This can also be applied to security cameras that can detect anomalies in patients’ and visitors’ behaviour and notify appropriate staff members.

A study published in the Journal of Medical Internet Research (JMIR) in 2023 demonstrated that combining AI and 5G in telemedicine significantly improved patient satisfaction and reduced consultation times by 30%.

Shaping an AI Blueprint for 5G eHealth

Integrating AI and 5G technologies can revolutionise disease assessment and surveillance, facilitating more precise diagnostics and tailored treatments. In return, it will drastically improve the standard of care, curbing expenses and boosting efficiency.

Over the next few years, healthcare providers should focus on specific areas where 5G and AI can deliver the most impact. For example, developing telehealth platforms that excel in security, accessibility, and user-friendly interfaces will be paramount. This design aspect is set to thrive, particularly with 5G paving the way for high-definition video consultations, remote patient monitoring, and instant data sharing between patients and healthcare

providers.

The precision and availability of diagnostic applications powered by AI and tele diagnostic services will notably increase in tandem with the widespread adoption of 5G. The strategic emphasis should be on enriching its capabilities, ensuring compatibility with existing systems, and seamlessly integrating the tech into existing healthcare processes.

AI-guided care management systems will also play an integral role in eHealth. There is a need to structure these systems to constantly monitor patient progress, suggest highly personalised treatments, and coordinate care across multiple providers while prioritising patient privacy and data protection.

Finally, when it comes to home health monitoring, emphasis should be placed on creating IoT devices that can integrate seamlessly with AI-driven health platforms and securely transmit data; this will be a critical development within the field.

The synergy between 5G technology and AI will continue revolutionising the healthcare industry, offering more customised, efficient, and cost-friendly solutions. By developing a precise AI blueprint for critical eHealth applications and capitalising on the capabilities of 5G, the benefits will drastically outweigh the challenges.

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Driving business success in today’s data-driven world through data governance

Source: Finance derivative

Andrew Abraham, Global Managing Director, Data Quality, Experian

It’s a well-known fact that we are living through a period of digital transformation, where new technology is revolutionising how we live, learn, and work. However, what this has also led to is a significant increase in data. This data holds immense value, yet many businesses across all sectors struggle to manage it effectively. They often face challenges such as fragmented data silos or lack the expertise and resources to leverage their datasets to the fullest.

As a result, data governance has become an essential topic for executives and industry leaders. In a data-driven world, its importance cannot be overstated. Combine that with governments and regulatory bodies rightly stepping up oversight of the digital world to protect citizens’ private and personal data. This has resulted in businesses also having to comply e with several statutes more accurately and frequently.

We recently conducted some research to gauge businesses’ attitudes toward data governance in today’s economy. The findings are not surprising: 83% of those surveyed acknowledged that data governance should no longer be an afterthought and could give them a strategic advantage. This is especially true for gaining a competitive edge, improving service delivery, and ensuring robust compliance and security measures.

However, the research also showed that businesses face inherent obstacles, including difficulties in integration and scalability and poor data quality, when it comes to managing data effectively and responsibly throughout its lifecycle.

So, what are the three fundamental steps to ensure effective data governance?

Regularly reviewing Data Governance approaches and policies

Understanding your whole data estate, having clarity about who owns the data, and implementing rules to govern its use means being able to assess whether you can operate efficiently and identify where to drive operational improvements. To do that effectively, you need the right data governance framework. Implementing a robust data governance framework will allow businesses to ensure their data is fit for purpose, improves accuracy, and mitigates the detrimental impact of data silos.

The research also found that data governance approaches are typically reviewed annually (46%), with another 47% reviewing it more frequently. Whilst the specific timeframe differs for each business, they should review policies more frequently than annually. Interestingly, 6% of companies surveyed in our research have it under continual review.

Assembling the right team

A strong team is crucial for effective cross-departmental data governance.  

The research identified that almost three-quarters of organisations, particularly in the healthcare industry, are managing data governance in-house. Nearly half of the businesses surveyed had already established dedicated data governance teams to oversee daily operations and mitigate potential security risks.

This strategic investment highlights the proactive approach to enhancing data practices to achieve a competitive edge and improve their financial performance. The emphasis on organisational focus highlights the pivotal role of dedicated teams in upholding data integrity and compliance standards.

Choose data governance investments wisely

With AI changing how businesses are run and being seen as a critical differentiator, nearly three-quarters of our research said data governance is the cornerstone to better AI. Why? Effective data governance is essential for optimising AI capabilities, improving data quality, automated access control, metadata management, data security, and integration.

In addition, almost every business surveyed said it will invest in its data governance approaches in the next two years. This includes investing in high-quality technologies and tools and improving data literacy and skills internally.  

Regarding automation, the research showed that under half currently use automated tools or technologies for data governance; 48% are exploring options, and 15% said they have no plans.

This shows us a clear appetite for data governance investment, particularly in automated tools and new technologies. These investments also reflect a proactive stance in adapting to technological changes and ensuring robust data management practices that support innovation and sustainable growth.

Looking ahead

Ultimately, the research showed that 86% of businesses recognised the growing importance of data governance over the next five years. This indicates that effective data governance will only increase its importance in navigating digital transformation and regulatory demands.

This means businesses must address challenges like integrating governance into operations, improving data quality, ensuring scalability, and keeping pace with evolving technology to mitigate risks such as compliance failures, security breaches, and data integrity issues.

Embracing automation will also streamline data governance processes, allowing organisations to enhance compliance, strengthen security measures, and boost operational efficiency. By investing strategically in these areas, businesses can gain a competitive advantage, thrive in a data-driven landscape, and effectively manage emerging risks.

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The Benefits of EV Salary Sacrifice: A Guide for Employers and Employees

As the UK government continues to push for greener initiatives, electric cars have become increasingly popular. The main attraction for both employers and employees is the EV salary sacrifice scheme.

By participating in an EV salary sacrifice scheme, both employers and employees can enjoy cost savings and contribute to environmental sustainability along the way! This article will delve into the specifics of how these schemes operate, the financial advantages they offer, and the broader positive impacts on sustainability.

We will provide a comprehensive overview of the mechanics behind EV salary sacrifice schemes and discuss the various ways in which they benefit both employees and employers, ultimately supporting the transition to a greener future in the UK.

What is an EV Salary Sacrifice Scheme?

An EV salary sacrifice scheme is a flexible financial arrangement that permits employees to lease an EV through their employer. The key feature of this scheme is that the leasing cost is deducted directly from the employee’s gross salary before tax and National Insurance contributions are applied. By reducing the taxable income, employees can benefit from substantial savings on both tax and National Insurance payments. This arrangement not only makes EVs more affordable for employees but also aligns with governmental incentives to reduce carbon emissions.

For employers, implementing an EV salary sacrifice scheme can lead to cost efficiencies as well. The reduction in National Insurance contributions on the employee’s reduced gross salary can offset some of the costs associated with administering the scheme. Additionally, such programmes can enhance the overall benefits package offered by the employer, making the company more attractive to prospective and current employees.

Benefits for Employees

1. Tax and National Insurance Savings

By opting for an EV salary sacrifice scheme, employees can benefit from reduced tax and National Insurance contributions. Since the lease payments are made from the gross salary, the taxable income decreases, resulting in substantial savings.

2. Access to Premium EVs

Leading salary sacrifice car schemes often provide access to high-end electric vehicles that might be otherwise unaffordable. Employees can enjoy the latest EV models with advanced features, contributing to a more enjoyable and environmentally friendly driving experience.

3. Lower Running Costs

Electric vehicles typically have lower running costs compared to traditional petrol or diesel cars. With savings on fuel, reduced maintenance costs, and exemptions from certain charges (such as London’s Congestion Charge), employees can enjoy significant long-term financial benefits.

4. Environmental Impact

Driving an electric vehicle reduces the carbon footprint and supports the UK’s goal of achieving net-zero emissions by 2050. Employees can take pride in contributing to a cleaner environment.

Benefits for Employers

1. Attract and Retain Talent

Offering an EV salary sacrifice scheme can enhance an employer’s benefits package, making it more attractive to potential recruits. It also helps in retaining current employees by providing them with valuable and cost-effective benefits.

2. Cost Neutrality

For employers, EV salary sacrifice schemes are often cost-neutral. The savings on National Insurance contributions can offset the administrative costs of running the scheme, making it an economically viable option.

3. Corporate Social Responsibility (CSR)

Implementing an EV salary sacrifice scheme demonstrates a commitment to sustainability and corporate social responsibility. This can improve the company’s public image and align with broader environmental goals.

4. Employee Well-being

Providing employees with a cost-effective means to drive electric vehicles can contribute to their overall well-being. With lower running costs and the convenience of driving a new EV, employees may experience reduced financial stress and increased job satisfaction.

How to Implement an EV Salary Sacrifice Scheme

1. Assess Feasibility

Evaluate whether an EV salary sacrifice scheme is feasible for your organisation. Consider the number of interested employees, potential cost savings, and administrative requirements.

2. Choose a Provider

Select a reputable provider that offers a range of electric vehicles and comprehensive support services. Ensure they can handle the administrative tasks and provide a seamless experience for both the employer and employees.

3. Communicate the Benefits

Educate your employees about the advantages of the scheme. Highlight the financial savings, environmental impact, and access to premium EV models. Provide clear guidance on how they can participate in the programme.

4. Monitor and Review

Regularly review the scheme’s performance to ensure it continues to meet the needs of your employees and the organisation. Gather feedback and make adjustments as necessary to enhance the programme’s effectiveness.

Conclusion

The EV salary sacrifice scheme offers a win-win situation for both employers and employees in the UK. With significant financial savings, access to premium vehicles, and a positive environmental impact, it’s an attractive option for forward-thinking organisations. By implementing such a scheme, employers can demonstrate their commitment to sustainability and employee well-being, while employees can enjoy the benefits of driving an electric vehicle at a reduced cost.

Adopting an EV salary sacrifice scheme is a step towards a greener, more sustainable future for everyone.

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