Treating Customer Fairly (TCF) Assessments

All firms regulated by the FSA have to support the FSA Handbook’s principle that a firm ‘must pay due regard to the interests of its customers and treat them fairly’.

The TCF (‘treating customers fairly’) principle aims to raise standards in the way firms carry on their business by introducing changes that will benefit consumers and increase their confidence in the financial services industry.

As the FSA move further towards “Principles Based Regulation” there is even greater emphasis on firms being able to demonstrate to the FSA that they have fully embraced the TCF concept and embedded TCF within their business.

The consequences of failing to do so have been clearly spelt out by the FSA and are evident from enforcement action that has been taken against a number of firms.

Whilst the FSA have produced an extensive amount of material setting out their requirements for regulated firms to deliver fair outcomes for their consumers, most firms struggle to identify what TCF means to their business and to develop an appropriate policy supported by relevant management information.

This is an area where it is particularly important for a regulated firm to have an independent external perspective on their TCF Policy. We have extensive experience of working with firms in all regulated sectors either reviewing the TCF Policy they have produced or structuring a policy that is appropriate for their business and helping them to embed TCF within their business.

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