Proving the TCF approach

You are treating your customers fairly

if you can prove:

c How TCF fits into your business activities and culture.

c How your behaviour takes account of the needs, risk appetite, level of understanding and rights of clients.

c How you market services.

c How you ensure your customers are provided with clear information and that it is understood by them.

c How you ensure your customers are given suitable advice according to their needs, circumstances, experience, and levels of understanding.

• How you manage your customers expectations

c That outcomes for customers have improved.

Notice the big ‘if’.

You want to treat customers fairly, you want to be able to prove this and you still want to run a profitable business. When principles-based regulation first came to the surface, many regarded TCF as carrying on as before. This has turned out to be a big mistake.

Many firms have learned the hard way that operating under a regulated environment is far different from a voluntary code of practice. However, the temptation is for firms to go too far down the compliance route at the expense of business. You need to get the balance right.

At Burns-Anderson we have drawn on our 20 years of experience of dealing with regulators to get to grips with TCF. We have already confirmed our TCF programme and our focus is to ensure that members are saved direct contact by the FSA.

We give hands-on support, one-to-one at the member’s firm. We help embed TCF so it becomes a benefit rather than a cost.

We are here to help. The more we understand you, the better we can support you.