Treating Customers Fairly
The TCF journey so far has been fraught with inconsistency and confusion in the industry.
Many firms still have far to travel in embedding TCF successfully and risk having a difficult relationship with customers and the regulator should they be assessed as having not successfully embedded TCF.
Huntswood's market leading approach to TCF has enabled our clients to:
- Proactively define what TCF means for their business;
- Develop a fast track evidencing and embedding framework; and
- Present a confident embedding TCF story to the FSA that deserves a 'light touch' supervisory relationship going forward.
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“There were three things that helped our business to get our TCF programme right, the FSA’s 6 consumer outcomes, customer analysis and Huntswood”
Head of UK Customer Services, large retail bank. |
Our market leading understanding and approach to TCF has enabled our clients to realise real benefits and confidently convince the FSA they have successfully embedded TCF culture.
Through working with some of the largest and most complex banking groups, life and pension firms and GI firms, Huntswood has developed an approach to TCF that has become recognised as market leading.
Our work on TCF now focuses on helping firms in three ways:
Firms that believe they met December 2008 deadline:
- Firms should seek independent third party assurance that they have met the deadline via a TCF embedding review. Firms that do this will not only demonstrate that they take the deadline seriously but will manage down the risk of failing to have their TCF achievements understood by the FSA.
Firms that believe they did not meet the deadline but have the potential to embed within a reasonable timeframe provided they refocus effort:
These firms are likely to receive an informal TCF risk mitigation plan from the FSA which will be closely monitored. Firms should focus effort on five critical areas:
- Migration of consumer outcome TCF MI suites into product lifecycle suites
- Review and redesign of consumer communications
- Face to face TCF training to develop staff understanding of what TCF means to their roles
- Design and implementation of SMART TCF performance objectives
- Effective stakeholder management of the FSA
Firms that failed to meet the deadline by a wide margin:
- These firms are likely to be served a TCF S166 from the FSA. There will however be a period of up to 2 - 3 months before the S166 review commences, allowing firms time to undertake a full refresh of their TCF effort which can significantly reduce the likelihood of enforcement.
