A broker's management information shows that customers who disclose a health condition are twice as likely as other customers to end up with a product that does not match their stated needs. What does the Consumer Duty require?
PRIN 2A.9.10R requires firms to identify whether any group of retail customers is getting different outcomes from others, and PRIN 2A.9.12R requires appropriate action where it does; FG21/1 expects outcomes for vulnerable customers to be as good as for others. A sale-by-sale check is not enough when the data shows a pattern. Refusing such customers would itself cause harm, and the Financial Ombudsman Service handles complaints, not firm reports.
Thinking individual suitability checks satisfy the Duty even when group data shows harm.
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