As intermediaries begin to count down to the 31 March 2008 TCF deadline, the AMI is taking matters into hand and urging them to implement proper TCF practices sooner rather than later.
As part of the campaign AMI will:
- Form a TCF working party involving key members of the industry
- Publish further, specific and more detailed TCF factsheets on separate strands of Management Information
- Launch a specific microsite on TCF
- Produce regular newsletters for members
Richard Farr, director of the AMI, said: "TCF will be a major focus for AMI in the coming months. It is vital we do all we can to help our members to embed a TCF culture within their firms. The FSA has said they will take action against firms that do not comply. The industry needs to make immediate changes.
“The FSA has recently published two documents relating to TCF, tackling the concepts of TCF Culture and TCF Management Information. Our latest factsheet summarises these documents and highlights some of the FSA’s examples of good and bad practice. Firms need to show clear leadership on TCF and encourage a good TCF Culture to evolve.
“Appropriate Management Information (MI) must also be collated. This information must then be used to educate staff about TCF and the processes involved. While many firms collect and review MI it is not always evident how they put it into practice. The FSA has said that this is the most important issue. Firms must be able to demonstrate they are using this information.”
Critical to TCF is the concept of Management Information. The FSA expects firms to demonstrate four main aspects of TCF MI:
- Integrating TCF into their business culture
- Appropriate MI or measures in place to test whether they are treating their customers fairly including delivering the six TCF consumer outcomes
- That MI demonstrates that the company is consistently treating customers fairly and delivering the consumer outcomes
- Processes in place that monitors the MI to enable the right people to take action.
