Many financial service providers (FSPs) aim to deliver positive outcomes for clients yet implementing the Treating Customers Fairly (TCF) Principles can be challenging. By leveraging key management data, FSPs can gain insights into client needs, identify potential issues early and foster a more transparent, client-centred experience.
Treating customers fairly shouldn’t just be a checkbox exercise – it should shape how FSPs operate every day. While most FSPs want to do right by their clients, turning good intentions into action isn’t always easy. That’s where the right management insights come in. With clear, targeted data, FSPs can spot problems early, stay in tune with client needs and deliver fairer, more meaningful outcomes.
This article looks at key management information indicators that support TCF, highlights common data-related challenges FSPs face and shares practical tips to overcome them.
Key management information indicators
Here are some key indicators that can help FSPs track their progress in achieving TCF:
- New business, cancellations, replacements and lapses registers: These offer a quick overview of client activity and can highlight issues around product affordability and suitability. They can also highlight risks such as inappropriate sales practices, poor disclosure, lack of informed decision-making or inadequate post-sale support – all of which can undermine TCF Outcomes.
- Complaints management framework: Complaints provide direct insights into customer experiences and can be tied to specific TCF Outcomes. For example, poor service may point to issues with Outcome 1, which requires FSPs to embed TCF into their culture by empowering employees to do the right thing and ensuring there are real consequences for unacceptable conduct. Delays in claims processing may indicate concerns with Outcome 5, which focuses on service standards. Barriers to lodging complaints or poor follow-up could signal a failure to meet Outcome 6, which aims to eliminate unreasonable post-sale barriers. These problems are often made worse when complaints aren’t managed in line with the established process or register – or when there are no consequences for failing to do so. It’s important to note that the FSCA has placed greater emphasis on complaints as a key conduct risk area, as reflected in its recent Complaints Management Industry Review Report. For more on this, see our related article. In line with the FSCA’s focus, our monitoring plan for FSPs in 2025 includes a focus on complaints during Q1, through both operational and sample checks. Where applicable, we also included conduct-based reporting and a TCF overview to help FSPs prepare for the areas under increased regulatory scrutiny.
- Client satisfaction surveys: Regular surveys, which the FSCA encourages, can give a sense of how satisfied clients are and where improvements may be needed. Aligning these surveys with TCF goals can help FSPs identify gaps in their service.
- CRM systems: A well-maintained customer relationship management (CRM) system can be a valuable source of information, helping FSPs track client interactions and spot patterns that could affect TCF Outcomes.
How to use these indicators to boost TCF Outcomes
Each of these indicators plays an important role in improving TCF Outcomes by identifying areas that may need attention:
- Registers can reveal patterns in client decisions that can point to deeper issues. For instance, a rise in cancellations or lapses may reflect unmet expectations or financial strain, while frequent replacements could signal gaps in the advice process. By interpreting these trends, FSPs can proactively refine their advice approach and product alignment to support fairer client outcomes.
- A complaints management framework offers real-time feedback that FSPs can use to delve deeper into issues. By identifying the root cause, FSPs can prevent similar complaints from arising.
- Client satisfaction surveys act as an early warning system for potential issues, helping FSPs address concerns before they escalate into complaints. They also offer a way to show clients that their feedback is valued, which can strengthen relationships.
By focusing on these indicators, FSPs can better align their actions with TCF Principles, leading to improved client outcomes and building long-term trust.
Common pitfalls in collecting and using management information
Collecting the right information – and effectively analysing and using it to promote TCF Outcomes – is often easier said than done, and many FSPs find it challenging. Here are examples of recurring difficulties that frequently trip up FSPs:
- Incomplete data collection: Although many FSPs maintain registers and logs, they often overlook key details like informal client feedback. For example, a client might casually mention dissatisfaction with a service to an admin staff member over the phone, but because it’s not a formal complaint, the concern is never relayed to the Representative or management. This lack of communication can result in missed opportunities to improve services.
- Underutilised information: Sometimes, data is collected but not fully analysed to get to the root of issues or complaints. This can mean trends or recurring issues slip through the cracks, impacting TCF Outcomes over time.
- Reluctance to gather negative feedback: Some FSPs shy away from gathering complaints or conducting surveys, fearing that negative feedback might reflect poorly on them. However, this feedback is essential for identifying areas needing improvement.
How to overcome these obstacles
Here are practical ways for FSPs to get the most out of their management information:
- Make data collection part of the daily routine: Integrate data collection into everyday operations. Keep registers, complaints and client feedback updated and reviewed regularly. This ensures data accuracy and helps spot trends over time.
- Use tech to simplify data collection: Technology can streamline how data is collected and ensure that key indicators are consistently tracked. For example, Masthead has tools that can help FSPs collect and analyse management information, such as complaints management tools and systems that link data directly to risk management processes.
- Run proactive client surveys: Don’t wait for complaints to come in – reach out with client satisfaction surveys to gauge how clients feel. If surveys aren’t receiving many responses, try using more accessible platforms like WhatsApp to connect with clients.
- Tie management information to risk management: By linking management information with your risk management plan, you can address negative trends before they escalate. This not only supports TCF compliance but also enhances business performance.
Better TCF Outcomes equals better business
Management information can be a game-changer for improving TCF Outcomes when used thoughtfully. By tracking key indicators like cancellations, complaints and client satisfaction, FSPs can identify issues early and make changes that benefit both clients and the business.
Moreover, refining how you collect and analyse data will not only lead to immediate gains in TCF – and in turn, increased client satisfaction – but it will also prepare you for future regulatory requirements. In the future, the FSCA’s Omni-CBR reporting will require detailed data submissions, and by enhancing your data practices now, you’ll be well-positioned to meet these new demands. The regulator also expects FSPs to use this data to address issues proactively, helping you stay ahead of regulatory changes, build client trust and secure long-term success.
Need assistance with collecting and analysing your management information indicators?
We’re here to help. To learn more about how we can support your TCF Outcomes, get in touch with us or contact the Regional Office closest to you.
Additionally, our Learning Centre’s TCF Overview Online Course explains the six TCF Outcomes and unpacks how to implement these across all areas of an FSP and throughout the product lifecycle. We also have a webinar, Treating Customers Fairly – How to Successfully Embed TCF Outcomes in Your FSP, which is scheduled to take place on 13 May 2025.