It's fair to say that I've spent more time behind my desk recently than I usually do. That's sometimes not a bad thing - especially for the IFAs and journalists fed up with listening to me going on and on about Liverpool beating Barcelona…
The reason for more time in the office? Well, in addition to all of the normal things we do in the team, we’ve spent a fair chunk of time in the last few months making sure that Treating Customers Fairly (TCF) is embedded into our culture.
It’s a big job and a serious one too. A few things pop up in conversations with industry people, when you mention TCF, that make for an interesting debate.
Recent research from Mortgage Next said just 6% of ‘small directly authorised firms’ are aware of the Treating Customers Fairly (TCF) 31st March 2007 deadline. This followed a survey by AMI which found that only 27% of advisers are aware of TCF. Just how many advisers are actually doing what they need to be doing? Why is communication not working here?
The key point with TCF is that you have to demonstrate how you apply it. Just saying you abide by your TCF principles isn’t enough. You have to prove it by showing it.
If I was to ask you who’s responsible for making sure you are behaving in a way that meets TCF requirements – what would your answer be?
If you are a network member, is it the network’s responsibility or your own? What about directly authorised advisers? What about tied advisers?
A good starting point is to forget about relying on someone else. YOU are responsible. YOU have to ensure that you can demonstrate that TCF principles are embedded in the culture of your organisation and the things that you and your team do.
If no-one has spoken to you about it by now it’s fair to assume that you need to do something about it yourself. So if you need help, where should you start?
Speak to your network contact if you are a network member. Ask them what tools they have available to help you and your firm to ensure that you can demonstrate your adherence to TCF principles. If you have yet to do anything about it, do it today – don’t leave it until tomorrow.
If you are directly regulated speak to the providers that you deal with. By now, the providers you deal with should have been through a process that reviewed all the things they do, and created a gap analysis of actions they need to implement in order to meet all of their TCF principles.
So much work has been done on this in certain areas, yet few organisations in the financial services arena are actually talking about it. Why? We’ve already seen a mess made by the industry of communicating changes to critical illness cover. Now it seems that TCF could suffer from a similar communications problem.
Don’t let it happen. Share your ideas and tools with your advisers and industry partners before it’s too late. Please…it’s good to talk!
Andy Milburn is IFA market manager at Royal Liver.
The views expressed are those of the author and not those of the company he represents.IFAonline
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