TCF Outcome 3 – Customers are provided with clear information and kept appropriately informed before, during and after point of sale. Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. Thematic reviews Incentive Complaints Suitability Structured products Whole of market/sector-wide review Firm/peer group review Product/thematic interventions Governance & behavioural effectiveness * - Financial Conduct Authority The reminder to firms to abide by the regulator’s TCF rules seemed a timely opportunity to revisit those requirements in more detail. All contracts to which AFS Groups Holdings Limited is a party are documented by other means. And what should you do to ensure your firm can achieve them? That’s the conclusion of a recent FCA review on practices surrounding equity release. [1]. 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. The focus from the FCA transitioned from TCF to a focus on issues that impact their consumer protection objective beyond the six stated TCF outcomes. Recognition that there is a need to formally identify any conflicts of interest between the firm’s commitment to TCF and other business goals and ensure these are analysed and managed Embedding TCF into existing group-wide customer service strategies, including training and awareness initiatives cascaded to staff all levels of the organisation Treating Customers Fairly (TCF) focuses on ensure fairness, clarity, transparency and due regard for consumers purchasing products/services in the financial, insurance and credit markets. Home page | Open Monday to Friday 9am – 5pm. Our blog looked at it in detail, and the implications for banks. 3. Any misleading promotions are likely to be met with fines and the enforced removal of ads and other materials. A firm must conduct its business with due skill, care and diligence. These remain core to what the FCA expects of firms. Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. ©2021 Asset Finance Solutions. 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 – RIGHT TARGET. The FCA has provided further detail on what it expects from firms, with six consumer outcomes “that firms should strive to achieve to ensure fair treatment of customers: Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of … language in the FCA’s documentation e.g. As we mentioned above, automation can be a huge help when it comes to mandating Compliance team approvals and compliant processes around your financial promotions. The principle of TCF must be driven by our company culture and the way we do business as opposed to a set of defined rules. Products and services need to meet the FCA’s standards on suitability; you can read tips on improving the suitability of your firm’s financial advice here. Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale. This is a core aspect of the FCA’s approach. A firm must conduct its business with integrity.. 2 Skill, care and diligence. Read tips on how to achieve this in our blogs on How to implement a culture of compliance and How to ensure your FP approvals meet FCA standards. FSA Desired consumer outcomes of TCF The FSA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative. It has clear rules about financial promotions compliance, many of which are focused around fairness and clarity. The six consumer outcomes explain what the FCA  want TCF to achieve for consumers. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly. A firm must conduct its business with due skill, care and diligence.. 3 Management and control. E. Treating Clients Fairly. A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.. 4 Financial prudence. The FCA needs you to prove you are acting in a compliant manner and treating the customer fairly. AFS Group Holdings Limited is not a lender or a broker and does not operate in the consumer finance market. The FCA has a number of tactics it can employ to challenge unfair and misleading promotions. One of the regulator’s statutory objectives is consumer protection and the principle of Treating Customers Fairly (‘TCF’) is reflected in PRA and FCA Principles for Firms, Principle 6 (‘Customers Interests’). One of the FCA’s overarching Principles speaks to TCF directly: – “A firm must pay due regard to the interests of its customers and treat them fairly.” As businesses, we have to be able to evidence these desired outcomes at every stage of the product life cycle. We develop and provide advice on sophisticated, bespoke products which are not available in the retail market. Fair consumer outcomes remain core to what the FCA expect of firms, the FCA will measure a businesses ability to provide consumers with the outcomes below, businesses that can’t evidence these will be subject to supervisions and potential sanctions: The FCA doesn’t lay down any standard way in which TCF should be assessed and implemented, but it has highlighted key areas within the product life cycle where it’s a good idea to have extra checks in place. 1. 1. Putting the customer at the heart of everything we do, and expecting the same attitude from firms. 27 pages) ... 11 FCA assessment of TCF outcomes delivery . Underpinning the TCF guidance are six consumer outcomes that the FCA states ‘firms should strive to achieve to ensure fair treatment of customers’. A firm must conduct its business with due skill, care and diligence.. 3 Management and control. Joining the AFS Head Office team as Group Legal Counsel is Suzanne Gadsby, Spencer Pilling has ‘finally’ joined Asset Finance Solutions, Information and customer support after the point of sale, Fact find and flow of information to the client (including after-sales), Record keeping and Management Information. 2: Skill, care and diligence. 7. Outcome 3: Consumers are provided wit… The Financial Conduct Authority's handbook lists 11 principles of business by which the watchdog expects all regulated companies to abide: 1: Integrity . These remain core to what we expect of firms. Please note that AFS Group Holdings Limited does not enter into any form of contract by means of Internet email. How to achieve the FCA’s 6 consumer outcomes, The fair treatment of customers has long been a priority for the financial regulator. James King Joins Jon Dufton at Amica Finance! 1 Integrity. 2. AFS and Synergy Commercial Finance are committed to supporting their network of brokers during the COVID-19 Crisis. 13 TCF enforcement and disciplinary issues. Attend our webinar where we will provide you with a good understanding of the six TCF outcomes, the areas within your FSP that require TCF implementation, how to implement the outcomes, and the types of Management Information needed to demonstrate integration into your FSP. Outcome 2. These include, In practice this means identifying potential gaps in TCF practice and developing procedures and checks to plug these in the following areas, AFS Group Holdings Limited is the parent company of Asset Finance Solutions (UK) Limited, Synergy Commercial Finance Limited and AFS Compliance Limited. Consumers can be confident that they are dealing with firms where the fair treatment of customers … Where consumers receive advice, the advice is suitable and takes account of their circumstances. 8. Automation and innovation and regulatory technology can help here. Outcome 3. There are six consumer outcomes that firms should strive to achieve to ensure fair treatment of customers. A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.. 4 Financial prudence. The good news is that there are some fairly simple steps you can take to improve your chances of achieving the FCA’s desired outcomes. D. 5. TCF Outcome 5 – Service is of an acceptable standard and products perform as customers have been led to expect. [1]. Where these directions apply the 'standstill', firms have the choice between complying with the pre-IP completion day rules, or the post-IP completion day rules. TCF 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. Your promotions need to include the relevant risk warnings and disclaimers – something that can be a bit of a lottery, as this blog explores. • The Treating Customers Fairly (TCF) initiative aims to deliver six improved outcomes for retail consumers – firms should be focused on trying to achieve these outcomes. 1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. As we mentioned above, this is particularly the case with vulnerable consumers. The Principles set out in simple terms the high level standards that all firms must meet. A firm must maintain adequate financial resources. The regulator’s consumer outcomes are not difficult to achieve, if you put in place robust procedures, make compliance approvals processes mandatory and put compliance at the heart of your organisation’s culture. The regulator is looking for firms to develop cultures where good governance is inbuilt, something we looked at recently in our blog on developing purposeful cultures. From understanding and upskilling to practical action Doing this means putting compliance at the centre of your processes; getting your processes up to scratch and ensuring compliant financial promotions, by making the necessary reviews, approvals and audit trails compulsory. We won’t be captured by rulebooks and procedure. • Conduct risk MI provides both a historical and forward looking view. There are two elements in this principle: I hope this will help you: TCF stands for Treating Customers Fairly. Underpinning the TCF guidance are six consumer outcomes that the FCA states ‘firms should strive to achieve to ensure fair treatment of customers’. In particular, it’s a good reason to look at the 6 ‘consumer outcomes’ that the regulator expects to result from firms treating their customers fairly. It’s a formal requirement laid down by the FCA to ensure that all financial services provided to consumers are done so in a way that isn’t detrimental to the customer. We’ll be far more focused in future on the consumer. The letter raised concerns flagged to the regulator about the way that some corporate customers were being treated during the coronavirus pandemic. These warnings will set consumer expectations about the way your products have performed. The FCA have defined consumer outcomes expected from a firm in the course of Treating Customers Fairly (TCF). TCF is a continuous process – it is not something that firms can implement and then forget about. How the FCA is supervising conduct issues … the FCA will be behaving differently from City watchdogs of the past. Important Information: AFS Group and CBILS (Coronavirus Business Interruption Loan Scheme), AFS supports Secrets Santa’s ‘Computers for kids’ appeal. There are four stages involved in bringing the TCF culture to the workplace. Over recent weeks and months, Compliance teams, like many other office-based roles, have adapted to a new world of work. TCF governance forums and committees business units Products Multiple FCA points of entry e.g. B. Where consumers receive advice, the advice is suitable and takes account of their circumstances: – … The FCA say, it's not possible to demonstrate you are actually delivering the TCF consumer outcomes without some evidence. Any organisation operating within credit management or account collection is expected to have appropriate management information and measures in place to ensure they are delivering the TCF consumer outcomes and comply with their regulatory obligations. Business Plan and Risk Outlook. Designed and built by Heckford. Recently, the Financial Conduct Authority sent a Dear CEO letter to banks reminding them about their obligations to treat corporate customers fairly. TCF stands for Treating Customers Fairly. They need to meet strict requirements on prominence to make sure they cannot be easily missed. Converting your client care promises into action is essential here to ensure your post-sales communications are as compliant as your financial promotions. TCF is a continuous process – it is not something that firms can implement and then forget about. Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint. The FCA say, it's not possible to demonstrate you are actually delivering the TCF consumer outcomes without some evidence. TCF Outcome 4 – Advice is suitable and according to the customer’s circumstances. How many TCF Outcomes are there? In March, the FCA shared details of its work to ensure the fair treatment of vulnerable customers. None of the staff of AFS Group Holdings Limited is authorised to enter into contracts on behalf of the company in this way. Treating Customers Fairly (TCF) is an outcomes based regulatory and supervisory approach designed to ensure that regulated financial institutions deliver specific, clearly set out fairness outcomes for financial customers. Marketing, advertising or sales material has to be clear, fair and not misleading. 3. 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. The FCA use them as an important factor in guiding regulatory decisions and actions. Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. The FCA plays a critical role in the UK economy ensuring that financial markets are honest, Treats Customers Fairly (TCF), small and large businesses and the UK economy as a whole These remain core to what The FCA expects of firms who deal with consumers of financial services. 12 Thematic work where TCF has played a role. "The statement that a process exists, or a control is in place, does not indicate that the process is followed all of the time or that the control is 100% effective in delivering the desired outcome." 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. A firm must conduct its business with integrity.. 2 Skill, care and diligence. 3: Management and control The FCA 11 Principles of Business are general statements of the main regulatory obligations that apply to firms that are regulated by them. Creating financial promotions that are relevant to your audience will get you another big regulatory thumbs-up. D. Trusting Customers Forms. 1. Consumers are provided with clear information and are kept appropriately informed before, during … The FCA have created a framework of six consumer outcomes to explain what they want TCF (Treating Customers Fairly) to achieve for consumers. But it also has relevance to financial promotions. Treating customers fairly (TCF): FCA requirements Practical Law UK Practice Note 7-379-7813 (Approx. We highlighted TCF as one of the regulator’s 7 priorities you need to be aware of in 2020, and last autumn explored how recent company failings had prompted a renewed push for TCF. 3. The FCA encourages firms to consider 6 consumer outcomes when implementing their TCF initiatives and in assessing whether the changes they are implementing are having an impact: Consumer outcome 1: Consumers must be confident that the firms they're dealing with treat customers fairly as part of their corporate culture. You can read more about how automating your processes can optimise regulatory compliance, as well as saving money and improving efficiency, in our whitepaper, The benefits of automated workflow systems. An integrated approach to managing conduct risk evolved that no longer focussed on the point of sale, The ‘stay at home’ guidance has seen Compliance professionals and their colleagues having to adapt overnight to remote operations. Any time you interact with customers or prospects, your approach needs to be compliant. To achieve this, make sure your Compliance team review and approval processes are robust, so no unapproved promotions slip through the net. 2. These outcomes are: Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of … Accordingly, this outcome is not relevant to our activities. These are: Outcome 1 ‐ Consumers can be confident that they are dealing with firms where the fair Consumers are provided with clear information and are kept appropriately informed before, during … What are these consumer outcomes? 2. The Financial Conduct Authority (FCA) is the conduct regulator for 56,000 financial services firms and financial markets in the UK and the prudential regulator for over 24,000 of those firms. … TCF Conduct risk From its creation in 2013, the FCA has taken a far broader approach to managing risks to customers. Principle 6 is singled out as being key to underpinning the need for firms to take particular care in the treatment of vulnerable customers and the FCA has re-iterated its six target outcomes for firms to achieve in the fair treatment of customers. E. 4. TCF continues to remain central to the FCA’s priorities and business plan year on year, with organisations being expected to embed and embrace the TCF culture and 6 desired outcomes. There are six consumer outcomes that firms should strive to achieve to ensure fair treatment of customers. Partly, of course, this outcome relies on product performance, and the robustness and market-worthiness of your solutions. • Less reliance on Caveat Emptor. • Firms should by now be seeking to make TCF an integral part of their business culture. In March, the FCA shared details of its work to ensure the, We highlighted TCF as one of the regulator’s, 7 priorities you need to be aware of in 2020, How to ensure your FP approvals meet FCA standards, rules about financial promotions compliance, Converting your client care promises into action, The benefits of automated workflow systems. Martin Wheatley March 2013 There are two elements in this principle: There are 6 desired outcomes to ensure that consumer interests are both respected and regarded and organisations regulated by the FCA are expected to embed TCF into the fabric of their business processes, services and products. We make no warranty and accept no responsibility for consequences arising from relying on this document. A firm must maintain adequate financial resources. You could say that the FCA are a sort of ‘financial bodyguard and protector’. TCF is a … The fair treatment of customers has long been a priority for the financial regulator. Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture. Privacy Policy. These will be used as the FCA monitors TCF against the … A new paper published by the Financial Conduct Authority’s ‘Insight’ arm suggests it might be. The FCA says: “Products and services marketed and sold in the retail market are designed to meet … Status: Please note you should read all Brexit changes to the FCA Handbook and BTS alongside the main FCA transitional directions. The FSB descibes it as follows: Treating Customers Fairly (TCF) is an outcomes based regulatory and supervisory approach designed to ensure that specific, clearly articulated fairness outcomes for financial services consumers are delivered by regulated financial firms. If your firm contravenes one or more of the Principles, it could face enforcement action, this could, for example, result in your firm’s authorisation being removed. A firm must conduct its business with integrity. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registra… Nothing in this document should be treated as an authoritative statement of the law. These remain core to what the FCA expects of firms. 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 – RIGHT TARGET. 3. C. 6. There are six consumer outcomes that firms should strive to achieve to ensure fair treatment of customers. The FSB wants to achieve six very specific desired outcomes that concern the customer. Action should not be taken as a result of this document alone. Common themes in TCF enforcement cases. After-sales communications also have to meet strict requirements. The six TCF outcomes. These outcomes are: What can your firm do to embed these outcomes in your financial promotions and operational processes? Where consumers receive advice, the advice is suitable and takes account of their circumstances: – … 4 Treating Customers Fairly Version: Draft FSA Desired consumer outcomes of TCF The FSA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative. The whitepaper is free, and you can download a copy from our resource library. We covered this in a blog on mortgage switching earlier this year, just one area where the regulator is keen to see fair treatment of existing customers. Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances. Outcome 1. consumer outcomes. A. Treating Customers Fairly. 1 Integrity. This states: ‘A firm must pay due regard to the interests of its customers and treat them fairly’. Treating Customers Fairly isn’t just a phrase any more. "The statement that a process exists, or a control is in place, does not indicate that the process is followed all of the time or that the control is 100% effective in delivering the desired outcome."