In many jurisdictions there has been heightened regulatory scrutiny on how financial institutions are dealing with borrowers in financial difficulty. When looking at the statements and criticisms’ that the regulators have made and what institutions themselves have self-identified, the issues may revolve around five key themes – vulnerable customers, due diligence/understanding customers, forbearance, communications and monitoring. In this global briefing note, we bring together regulatory developments in a number of jurisdictions under these themes, which in turn provide a useful checklist for institutions to utilise, mitigating potential conduct risk challenges.
