Treating Customers Fairly III

Outcome 3 - Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

Have you updated your initial disclosure material or terms of business to reflect the FSCS changes announced in January? Do your client files consistently record details of information obtained from and provided to the customer? Is the file up to date?

Can you demonstrate that all of your communications are clear, fair and not misleading? your marketing material - do you ensure that any information is "balanced" and important exclusions are prominently disclosed? Would it pass the "mother in law test?"

Where you have more than one adviser working within the business are you satisfied that all advisers operate to a consistent high standard? Are any issues identified as part of the monitoring process recorded and appropriate training provided to avoid any repetition?

How satisfied are you that Customers have a good understanding of information that you have provided? Can you prove it?

Treating Customers Fairly assessments East Anglia

The FSA have announced the next programme of Treating Customers Fairly Assessments and these are to take place in September and October 2010.

As previously, the assessments will be either by telephone or face to face at a central location.

To help Firms, the FSA are holding a series of TCF Roadshows in the "Region"


Orsett Hall Hotel, Orsett (Essex) 21st and 22nd June.

Huntingdon Marrott Hotel, Huntingdon 7th and 8th July.

Eastwood Hall, Nottingham 21st and 22nd July.

Firms are permitted to send a maximum of two delegates per Firm and bookings need to be made by 28 May. As places are limited it is advisable to reserve a place early.

In July the FSA will inform Firms when their specific assessment will take place and ask for pre assessment information - see my previous article for details.

Those Firms that have policies in place; good management information to support the six key outcomes and have a top to bottom tcf culture have nothing to fear.

Those with issues may be torn between watching the footy and updating their gap analysis.

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%

The Golden Fleece?

...before you ask, it is the name of the Pub that I am writing this blog from in the City :o)

Back to the script.

1st December 2001 was an interesting day - the Birth of the Financial Services Authority (FSA) as we know it today. Will it make its 10th anniversary - I wonder?

Another shuffle of the deckchairs as NASDIM became FIMBRA, which merged with LAUTRO to form the PIA. Then all of the SRO's combined to form the FSA - a single unified Regulator with clear statutory objectives of :


Market confidence in the financial system;

Promoting public understanding of the financial system;

Investor / Consumer protections

Fighting financial crime.

In 2003 no one saw it coming - the FSA, with a detailed set of Rules shifted to "Principles based Regulation" - focusing on outputs rather than strict adherence to detailed rules. How is what you are doing supporting Treating Customers Fairly?

Simply having a happy customer didn't mean that you had treated them fairly and many accepted customs and practices had to be revisited and tweeked. Firms were given ample time to implement TCF within their businesses - and collect management information to be able to prove how Treating Customers Fairly was embedded within their business. Easy when you know how - ask me :o). And then the FSA Interviews started.