Getting Tough on TCF

NewCOB (or COBS) may be an attempt by the FSA to refocus on advice being principled, but the FSA is keen to show that it is far from toothless when it comes to enforcing its standards on TCF (Treating Customers Fairly).  Recent reviews have resulted in seven firms being listed for enforcement action, plus further reviews and actions being taken in relation to more than 65 other firms - and that's just in relation to mortgage advisers.  A similar picture has emerged for intermediary firms, although on the whole compliance with TCF appears to be of a consistently better standard within IFA firms.

The FSA expects that regulated firms will be able to demonstrate that they are achieving all six TCF outcomes by the end of December 2008.  Just by way of a reminder, here they are:

1. Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
3. Consumers are provided with clear information and are kept appropriately informed before, during, and after the point of sale.
4. Where consumers receive advice, the advice is suitable and takes account of their circumstances.
5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and also as they have been led to expect.
6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Of these six outcomes, items 1, 3, 4 & 5 are of most relevance to the intermediary market.  At 2020FS, we have designed a TCF Kit for our Members, which is aimed at helping firms plan their TCF initiatives.  More relevantly, we have written the Our Business Process (OBP) template, which describes every aspect of your business process from the perspective of TCF and the client's experience.  A little later in 2008, we hope to make available Financial Advice Project-Books to help Member firms establish consistent standards, and accurately reflect client circumstances, objectives and priorities.  Please contact us on 02920 494495 for further information.