Most of the institutions interviewed had taken into account the vulnerability of elderly customers in the marketing of financial products, although to varying degrees. They had implemented actions to identify this vulnerability and to assist financial advisors in managing relations with these customers. It is obvious that the financial advisor plays a central role in the relationship with vulnerable elderly people; as a result, the main focus for the institutions encountered was on developing support measures for advisors.

However, this cannot be the only bulwark against the risk of inappropriate marketing to an ageing client population.

For this reason, some institutions have sought to develop a more comprehensive approach based on the three paths recommended by the AMF and the ACPR, understood as a coherent and holistic whole.

Noting the wide disparity in the implementation of measures by institutions, the authorities encourage all institutions to continue their efforts to provide due protection for vulnerable elderly customers, who were specifically addressed in the bilateral interviews.

The ACPR and the AMF reaffirm the importance of developing preventive action by training advisors and setting up Referral Managers who can be organised on an individual or collective basis. They also stress the need for institutions and groups to include a proactive policy in their inspection programmes to prevent the risk of inappropriate marketing to vulnerable populations. They advocate that this preventive action be organised as part of an appropriate governance system, that notably includes regular reporting to decision-making bodies on the outcomes of the actions taken (analysis of the system put in place, results and malfunctions identified, measures/changes planned or implemented). The practices described below may be a useful source of inspiration that the authorities would like to share with the financial community with a view to increasing such active vigilance.