Time for TCF

‘Why put off tomorrow, what you can put off today?’ I once read this in one of those tomes that you find in department stores about this time of year, presented as the ubiquitous ‘stocking filler’ – any decent book retailer avoids them like the plague.

I guess it was an attempt to be humorous. In fact, I think the whole book was an attempt at being humorous.

Being generous, I can see that it is perhaps a mild truism that procrastination can be a bit of a national pastime and in its meaning it has its own ironic form of procrastination.

However, it is positioned as pseudo-wisdom and there belies the reason why it is not funny. As wisdom it serves no practical purpose and therefore isn’t funny.

Not getting necessary, albeit dull, scary or annoying stuff done is destructive. For example, think of the consequences of not doing the mundane, frightening or frustrating; brushing your teeth; going to the dentist for root canal work; getting on an NHS dentist’s waiting list in the first place. Look what procrastination did for Jocky Wilson.

Management information

So, it is without question that this attack on procrastination is going to lead me to the deadline of the next stage of the Financial Services Authority’s (FSA) ‘Treating Customers Fairly’ (TCF) initiative.

The fact is that organisations must, by 31 March 2008, be demonstrating that TCF is embedded in their culture by means of ongoing management information.

Now, even if some of the management information exists already, in the form of, let’s say, ‘number of complaints’ or ‘monthly product sales and splits’, it is not an overnight job to figure out what else is needed, and then build the reports, queries or spreadsheets and put an ongoing program together.

But you must start planning now so that your implementation starts no later than the New Year so you have a quarter’s worth of management information before the deadline – this is not something that can be pulled together at the last minute.

Small firm difficulties

Small firms seem to find relating to this particularly difficult. I can understand this – on one hand the FSA has done away with the sole-trader controlled function, in an acknowledgement that sole traders can hardly supervise themselves, and then insists that a sole trader produces their own management information for review.

Perhaps the best analogy I’ve seen is that of a mobile phone bill. You know what calls you’ve made and what text messages you’ve sent. However, by reading the bill you can get an overview of the information you already know and you can pick out trends. Do 10 per cent of your cases fail to get from submission to offer, but actually that rises to 45 per cent for ABC lender?

Does your administrator spend a disproportionate amount of time placating clients when you use XYZ insurer? Compiling this kind of data and presenting it to yourself may help to identify patterns and then rectify problems of which you were really unaware, but which were eating into your valuable time.

A helping hand

When reading this, if your firm hasn’t yet started then you have a couple of things to help you on your way. First, the industry is gearing up, putting out websites, articles like this one, running awareness campaigns, training days and factsheets.

AMI itself has convened a working group of experts, from large networks to small practices, including FSA representation. The purpose of the working group is to offer intermediary specific guidance through a microsite and factsheets between now and the deadline, with particular focus on small firms.

The second helpful, although perhaps unwanted circumstance, is current market conditions. I could have been sympathetic over the protestations of getting TCF embedded by the deadline with the market performing how it has done over the last three years.

However, property market volumes are slowing and with tighter criteria the numbers of remortgages are also slightly falling. Admittedly time will be spent fighting for new business and placing business could require a little more effort, but this is perhaps the perfect time to expend the effort to get your TCF managment information up to scratch.

My prediction is that the market will start coming back after the big American investment banks file their year-end accounts. So some time after the first quarter. Hmmm... that date again...31 March 2008.