Treating Customers Fairly

• Understand that TCF is a cultural imperative, not just a process
• Appreciate that TCF must be part of doing business as usual
• Understand the rationale behind the regulatory requirements and appreciate why some customers need a little more care than others
• Be able to set up new or improve/enhance existing processes to comply fully with the obligations of a regulated firm
• Recognise that it is the spirit of these rules that is important not just the letter
• Understand what good practice looks like and be able to recognise and avoid the poor practice

Introduction

• What is TCF
• The relationship between TCF and the Principles for Business:
  • Principle 6 – ‘A firm must pay due regard to the interests of its customers and treat them fairly’
  • Principle 2 – A firm must conduct its business with due skill, care and diligence.
  • Principle 3 – A firm must take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems.
  • Principle 7 – A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.

The 6 TCF Customer Outcomes

• Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change products, switch providers, submit a claim or make a complaint.

TCF In practice

• What do TCF outcomes mean for the business and customers
• Distinguishing between fair and unfair customer treatment - making the connections
• The product life cycle and the customer touchstone moments across your product life cycle
• Culture and fair treatment of customers - drivers and indicators
• The responsibilities and expectations of senior executives
• The management information that demonstrates your fairness is at the heart of the business.

Embedding TCF within a firm’s culture

• Identifying areas where TCF issues are most prevalent
• Achieving management buy-in
• Real TCF Scenarios Enforcement of TCF
• Staff training and competence
• Customer feedback

The trainer had a highly successful, long and varied “fast track” career in Lloyds Bank which led him to a very senior management position in the bank’s private banking and wealth management division at an early age. He was then “headhunted” to join a merchant bank at the main board director level to head the risk management function. He now has over 40 years of experience in the UK banking and financial services sector. He volunteered in both his career roles to design, create and deliver soft skills training to colleagues at all levels of seniority mainly because he enjoyed it and received consistently good feedback from delegates.

He has been a freelance soft skills training consultant since retiring and is currently an external Master Trainer at both HSBC and Bank of China where he has delivered soft skills training on a wide range of topics. At HSBC he helped screen and assess both prospective and existing trainers for soft skills capabilities and has delivered train the trainer programmes. At Bank of China he has designed and delivered successfully a comprehensive presentation skills programme. He has created and delivered soft skills training to a vast range of clients, from global giants to small firms and partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, USA, South America, Europe, Africa, Asia and the Middle East.

The trainer is a highly adaptive, hands-on and highly sought after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience, from “black belts” to novices. In addition to his soft skills specialism, his expertise includes but is not limited to Risk Management, Trade Finance, Regulatory Compliance, FCC & AML and all aspects of Corporate, Private & Retail Banking.

Treating Customers Fairly (TCF) is a mandatory requirement of the Financial Conduct Authority (FCA) and impacts all regulated firms. It requires them to “pay due regard to the interests of their customers and treat them fairly.” The objective of the FCA is to build consumer confidence in the financial services industry.

The FCA requires Treating Customers Fairly to be “embedded” into a firm’s culture. This is not the same as “awareness”. Firms must adopt compliant practices such as giving the customer what they have paid for, not taking advantage of them, offering the best product possible, making an effort to resolve complaints quickly, showing flexibility and empathy and being clear, fair and not misleading in all customer dealings.

Firms that fail to treat customers fairly can receive large financial penalties from the FCA and suffer repercussions.