The FSA has brought forward the date from which it will fully integrate TCF into its supervisory work from September 2009 to January 2009. Jon Pain, managing director of retail markets at the FSA, stated that the announcement means: "the FSA can deliver the benefit from the TCF programme more quickly. Our focus will be on the outcome for consumers. We will continue to challenge firms rigorously where there are issues and take decisive action where necessary." Please click here and here for previous blogs on TCF.
From January 2009, TCF compliance will be included in regular ARROW assessments of firms. This will involve a review of the TCF outcomes with reference to the firm's own management information; direct testing of the consumer experience (through call listening, mystery shopping and reviews of consumer communications). Feedback on TCF compliance will be given to firms through risk scores assessed during the ARROW assessments and will be ranked from low to high. The recent FSA publication on TCF can be found here.
On 18 November 2008, Sarah Wilson, Insurance Sector Leader and Director of TCF at the FSA, gave a speech on TCF and "what good looks like". She said that a firm which consistently treats its customers fairly is one which:
- is able to demonstrate that senior management has instilled a culture whereby it understands what the fair treatment of customers means; where it expects its staff to achieve this at all times; and where (a relatively small number of) errors are promptly found, put right and learned from;
- is appropriately and accurately measuring performance against all customer fairness issues materially relevant to its business, and acting on the results;
- is demonstrating through those measures that it is delivering fair outcomes; and
- has no serious failings – whether seen through MI or known to us directly – including in areas of particular regulatory interest previously publicised by the FSA.
Please click here to read the speech in full.