TCF is a main plank of customer focus and this concept should feature regularly within Board debate. There should also be management information supplied either separately or within a compliance report to gauge the firm’s on-going behaviour towards customers.
The six required TCF outcomes are:
- Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture
- Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly
- Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
- Where consumers receive advice, the advice is suitable and takes account of their circumstances
- 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
- Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint
Where the firm does not have direct dealings with the ultimate customer, the regulator will expect the firm to be mindful of the intermediary chain. Additionally, prudent action should be taken to support the principle of TCF by passing on appropriate information such as product detail and explanations; particularly where it is perceived that the quality of the chain may be lacking in some respect. The firm will be expected to have an interest in customer facing issues such as contract certainty, complaints and conflicts of interest.
The FCA will seek to ensure that wholesale markets are efficient, orderly and fair and that retail customers do not suffer undue detriment from wholesale activities.