TCF with threesixty
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"The FSA believe that only 41% of intermediaries have actually met the March deadline for implementing their TCF initiative and have confirmed that they will consider enforcement action against those firms who have not met their requirements.
We know that threesixty client Firms have successfully implemented their TCF objectives, and are in a position to provide documentary evidence to support this. These Firms have done so by attending our TCF workshops, following the processes described and subscribing to our ongoing audit services."
David Brattesani, Partner at threesixty |
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As you know, the FSA set a deadline for the end of March 2007, for intermediaries to successfully demonstrate that they had implemented the Treating Customers Fairly initiative within their businessand that this should be fully embedded within the firm by the end of 2008.
TCF requires each intermediary firm to:
• Create a clearly defined set of objectives with regard to TCF
• Undertake a gap analysis, to establish which elements of the firm’s systems and controls require attention in order to met the TCF objectives
• Create a TCF Plan
• Communicate both objectives and plan to advisers and staff
• Review feedback from advisers, staff and customers
• Amend the TCF Plan, as necessary
The FSA believe that only 41% of intermediaries have actually met the March deadline for implementing their TCF initiative and have confirmed that they will consider enforcement action against those firms who have not met their requirements. The FSA’s TCF review project assesses the position of firms initially by interview and then where necessary by follow up visit.
We know that threesixty client Firms have successfully implemented their TCF objectives, and are in a position to provide documentary evidence to support this. These Firms have done so by attending our TCF workshops, following the processes described and subscribing to our ongoing audit services.
The following comment, made by Martin Simms of Matrix Model, is typical of the positive feedback which we have received with regard to threesixty’s TCF Support.
“I just wanted to drop you a quick ‘thank you’ for the guidance you’ve given our firm in relation to treating customers fairly (TCF).
Having attended the threesixty training day on this subject, I have gained a clear understanding of what TCF means in the eyes of the regulator, and how we can benefit from reviewing our various procedures. Since undertaking the staff and client survey that you helped with, we have altered some of our processes to the benefit of both the clients and our firm. Its early days yet, however we are starting to see more opportunity for referrals from existing clients, as our processes ask for their feedback and confirm our interest in their views.”.
We will continue to build on the support which we have provided to date, via ongoing audits, standard documents and regular updates.
Alhough the December 2008 has past the FSA’s project of review is ongoing. FSA TCF reviews is likely to form part of the ongoing supervision of small firms even after the initial project has completed as they will revisit regions to assess progress since the last assessment.
Our clients have demonstrated a consistently high standard to date, and it is important that we continue to provide the support necessary to demonstrate an ongoing commitment to TCF.