FSPs are expected to embed TCF in their business models and culture, ensuring that customers are at the heart of everything they do. FSPs must be able to demonstrate that they consistently treat their customers fairly and are delivering their services in a way that will ensure TCF outcomes for their customers, relevant to their business.
Here are a few tips to assist in ensuring that TCF is at the heart of your practice:
1. Set the tone from the top
Make it clear that the goals and objectives of the business include treating customers fairly. The values and culture of the business must be set by management and must embrace the principles of TCF.
2. Train all your staff on TCF
Ensure that all staff understand what it means to have TCF built into the business culture and how their role fits into this culture.
3. Implement a TCF policy
A documented TCF policy should set out the business’ commitment to uphold the culture of treating their customers fairly. It should stipulate how the TCF outcomes apply to the business, how staff are trained and how TCF is monitored in the business.
4. Record and maintain client correspondence
TCF requires FSPs to embrace best practice and to be able to evidence this through effective record keeping. Ensure that you keep a record of all communications with clients, that can be provided on request.
5. Review your communication methods
It is important to review all methods used to communicate with clients, this includes letters and emails; product information; your website and marketing literature and the way your staff speak to your clients. Central to the principles of TCF is that information must be clear, fair and not misleading to enable the client to balance potential reward against risk and to make an informed choice. All communication must also be targeted to the appropriate audience.
6. Implement a complaint handling procedure
The area of complaints is intrinsically linked to TCF. FSPs must ensure that clients can complain, and that any complaint is dealt with reasonably, promptly and fairly. The FSP should use complaints statistics to improve standards which will lead to improved client outcomes. This will also build client trust and loyalty.
7. Record Management Information
Management Information can be both qualitative and quantitative and can include things like client surveys, compliance checks, press coverage and conventional Management Information. FSPs must ensure that the information is not just “collected” but is also reviewed regularly and any risks to fair client outcomes or areas of non-compliance remedied. Management Information data or statistics should be collected to measure performance in all areas of the business and drive change for improvement where needed to better the TCF culture.
8. Conduct TCF assessments
TCF assessments can take various forms and may include “mystery shopping”, randomly reviewing files and listening to staff calls. It’s important that FSPs monitor how well TCF is understood by their staff and integrated within their business.