Treating Customers Fairly (TCF)
Current state of play
As of December 2008, the FSA expects firms to be able to demonstrate to themselves and to the FSA that they are consistently treating their customers fairly.
Originally this involved FSA assessments of firms from September 2009 onwards – however, this has since been bought forward to January 2009 and assessments, using the ARROW framework, are already part of the FSA’s core supervisory work.
The 6 TCF Outcomes expected by the FSA:
- Fair treatment of customers is central to the corporate culture
- Consumers must be marketed and sold products that have been designed to meet their needs
- Clear information must be provided to consumers and they must be kept informed during and after point-of-sale
- Advice given must be suitable and take account of all the consumers’ circumstances
- Both the product bought and service provided to consumers must be as the consumer has been led to expect
- Consumers do not face unreasonable barriers to switching, claiming on a product or complaining
How we have helped our clients
FSA TCF assessments will include direct testing of the consumer experience and reviews of firms' management information
Qualitative depth interviews amongst recent purchasers of an Equity Release product on behalf of a leading UK Friendly Society
Key objective to assess whether or not customers understood key aspects of the product e.g. charges and fees, what happens if the property is worth less than the loan after the loan is repaid
Also, whether or not other possible ways of raising finance had been discussed prior to purchase
A series of group discussions, depth interviews and client participation workshops with consumers and financial advisors on behalf of a leading UK fund manager
Draft marketing literature had been designed to support the imminent launch of a new Absolute Returns Fund
The research gave clear recommendations as to how the literature should be improved so as to make clear certain product specifics and the risks involved for potential investors
