Stepping up to the mark

One of the risks that firms may have taken in ensuring that they hit last year’s Treating Customers Fairly (TCF) deadlines was in trying to take existing management information and finding ways of making if fit with the TCF outcomes. The problem with ‘Shoehorning’ existing management information to fit an alternative purpose is that while it may have highlighted some of the critical gaps, it may not be until further down the line when the gaps in the evidence gathering start to emerge. In order to meet FSA requirements, it is critical that any TCF procedures are fit for purpose and, even...