Treating Customers Fairly - I

We can all remember when we last received good or exceptional service from a supplier - how did you feel about them and what did you do about it? I recently had a slow puncture and took my car in to the local Kwik Fit garage. Whilst waiting to speak to the chap behind the desk I noticed that they now do car servicing. Having left the keys I went back to the office.

A few hours later I got a phone call - Mr Cass, your car is ready. They were also open until 6pm and I was able to finish my afternoon meetings before collecting the car. How much was the bill I asked? The manager said - no charge - you are a regular client and it was only a faulty valve. No prizes for guessing where I will be taking my car for servicing from now on.

But a happy and content customer doen't mean that you have treated the fairly. Ignorance is bliss - until someone points the error of your ways. So what does this mean for Regulated Firms?

The FSA has set 6 key outcomes that they expect Firms to adhere to.

Outcome 1 - Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

So, can you prove it? What management Information do you have available to demonstrate that you are complying with outcome 1?

Have you completed a Treating Customers Fairly self assessment/gap analysis and then produced an action plan? Have you reviewed and repeated this exercise at least annually?

If you have retained the services of an outside Compliance consultant - have they undertaken an independent assessment / peer review?

Have you asked members of your team for their ideas? Is this a regular topic at team meetings and has it been recorded?

Do you have square pegs and round holes? Have you recruited the right people to do the right jobs and have they been trained and coached accordingly? Does their ongoing CPD include TCF?

Testing and measuring - what monitoring and feedback are you providing - staff performance against relevant TCF related measures?

Have you set SMART Key Perfomance Indicators? (for example, key performance indicators in areas such as complaints received, cancellations, lapses,
products sold by type/provider etc.)

Are you providing the leadership and direction to your team? Is it TCF focused?

How do you handle any conflicts of interest?


This is not an exhastive list but as you can see - the bar has been set high by the FSA. Most Firms do have a TCF culture - treating their customers as they expect to be treated; keeping their promises and offering good customer service and fair value. After all, if we dont look after our clients then there are plenty of Bankassurance direct salesmen/women that would love to flog policies to your clients. Pity that the FSA seems to focus on IFA's who generate 3% of FOS casework -rather than on the Big Institutions who account for the othre 97%