The AMI census showed 19 per cent of members had ‘embedded’ TCF in their business and 29 per cent were currently implementing it. While 20 per cent of members were at the ‘strategy and planning’ stage and a further 27 per cent were ‘aware’ of TCF, 85 per cent of firms were confident their strategy would be in place by the Financial Services Authority’s (FSA) 31 March deadline.
Of the 72 per cent of brokers to conduct a TCF review, 57 per cent had made changes as a result. However, time was found to be the major barrier to implementation, along with understanding how to implement TCF, staff resources and the cost to the firm.
Rob Griffiths, associate director of AMI, commented: “It is pleasing to see firms are confident they will hit the deadline, yet a large number of firms still have work to do. Firms must actively engage in the TCF process and a review and gap analysis must be carried out.”
Nick Baxter, managing director of Mortgage Promotions, said: “I would strongly recommend intermediaries to read the most recent FSA newsletter, as it makes it clear what is requred. It’s a bigger exercise than most people anticipate, as often the most difficult part is analysing your own business at the start.”