The FSA’s Treating Customers Fairly (TCF) initiative was first introduced by the FSA in its publication ‘A new regulator for a new millennium’ and has resulted in a year on year running thematic programme encouraging organisations to embed into their businesses responses for ensuring that customers interests are regarded and that they receive fair treatment.
Since 2001 FSA has carried out both research and a series of theme visits to evaluate how organisations treat their customers. Subsequent FSA publications have provided organisations senior management with guidance on how they should co-ordinate their internal TCF initiatives as well as matters that have caused the FSA concern.
The FSA expect's organisations to consider TCF in respect of their activities in:
- product design
- marketing, including the production of promotional material and disclosures
- the sales process, including advice where that is given and the information provided to consumers as part of the sales process
- the way that staff are remunerated
- information and customer support after the point of sale
- complaint handling and
- management information
From reviewing your financial promotions, to designing new products and services, to the construction of contract terms and conditions, the Treating Customers Fairly (TCF) initiative is already having an impact on your business.
The key challenge is how your business responds to this ’principle-based‘ initiative, how it rises to the challenge of ensuring compliance, whilst identifying measurable performance improvements.
Businesses that adopt and embed appropriate TCF practices should benefit from long-term reductions in the cost of compliance, and will drive-up client loyalty by delivering exceptional customer service.
Our experience, in the mortgage and GI markets in particular, will help you to refine your TCF strategy, and ensure that those areas in sharp regulatory focus are not overlooked. These areas include: quality of advice, the explanation of ’risk‘, assessing client needs, policy exclusions and limitations, and systems and controls.
How we can help
- Training and education
- Advice on establishing a TCF initiative
- Project management to support your TCF initiative
- Technical assistance to support your understanding of your TCF obligations,
- Supply you with interim/ seconded compliance resource to support your compliance arrangements
- Review and report on the adequacy of your TCF project
- Establish MI and advise on how best to use the information to improve the way you treat your customers fairly.
In summary, we will support and advise you on ways to consider the needs of your customers at all stages of the product life-cycle; and, help you to establish the requisite MI needed to monitor the success of your TCF strategy.
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