Do you know FSA’s six TCF outcomes? No doubt you do: it’s not hard to find them.
Have you remembered FSA has now embedded TCF compliance into its regular ARROW framework? Probably: it’s been well publicised.
Does your firm have an embedded TCF culture that starts at the top? Hopefully: it’s been a key message.
Are you confident you can show your firm consistently delivers fair outcomes for customers? That’s trickier. You can document what you’ve done over the past few years, you can produce your fair product terms and you can prove you’ve told your staff what the outcomes are. But how can you show you have instilled the right culture? What systems and controls will FSA expect to see that measure TCF, and pick up and deal with problems?
In one short note, we can’t give you all the answers. But we can highlight some areas we think are critical to showing FSA you’ve got your TCF right.
Where can you show compliance?
You need to “build in” TCF:
- to every part of your firm’s governance model;
- in staff development; and
- in every stage of your relationship with customers.
If you don’t do this, it will be difficult to achieve the outcomes. Getting the first two right – Governance and Staff Development – will be crucial in ensuring the third and most important area – your Customer relationships – is TCF-compliant.
The tables below explain what we think are some of the key ways to help you prove you’ve got it right.
It’s not only TCF
Firms also need to address other parts of the fairness agenda, including the Unfair Contract Terms in Consumer Contracts Regulations and the Protection from Unfair Trading Regulations. Banks will have to implement BCOBS and the extension of TCF to deposit-taking