TCF is by far the biggest current thematic priority, and the FSA have made clear that it is all-embracing. Having begun the work with larger firms some time ago, the FSA now expect all firms whose business affects retail customers in any way to be well engaged with TCF implementation. Having set a deadline of end March 2007 for firms to have made significant progress in implementing TCF in a significant part of their business, FSA have now set new deadlines. By the end of March 2008 firms are expected to have appropriate Management Information or measures in place to test whether they are treating their customers fairly, and by the end of 2008 all firms are expected to be able to demonstrate to themselves and the FSA that they are consistently treating customers fairly.
There is a large body of case studies and similar material available on the FSA website to help firms with TCF reviews, but for many it may be difficult to know where to begin. We can help. For example:
- we can brief you on the background to the exercise and its objectives, to help you get up to speed and formulate plans for an in-house review;
- we can help you with the conduct of the review itself, its documentation, and the development of solutions to any problems identified using mystery shopping type techniques or testing by putting ourselves in the customer's shoes;
- we have a simple, practical methodology for conducting a TCF gap analysis which can both highlight areas of strength and identify priority areas to work on;
- we can help design your TCF management information to help understand and demonstrate where you are or are not treating your customers fairly;
- we can complement and add value to your own review by providing an independent perspective on strengths and weaknesses, perhaps drawing attention to wider issues you might have missed.
See also our December 2007 Briefing Note on TCF.