How can IFAs help themselves on TCF?

The thing is if you ask many IFAs what this actually means in practice they can’t really tell you. If you ask the compliance consultants, they will tell you to implement a big unwieldy plan (as well as money laundering plans, compliance plans, business continuity plans and all the other business plans they tell you to do), but the reality is that these TCF plans are a sledgehammer to crack a nut and TCF shouldn’t be anything more than good business practice. I personally think you can satisfy most of the FSA requirements on TCF by ensuring all your normal systems and controls are relevant...