The deadline was issued in last summer’s FSA publication ‘Treating Customers Fairly – towards fair outcomes for consumers’. In it, the FSA said that by 31 March 2007 it expected all firms to have ‘implemented TCF in a significant part of their businesses’. The FSA have said that a firm is at the ‘implementation’ phase when it is:
- Developing plans and processes;
- Allocating TCF resources and responsibilities; and
- Creating capability among its staff.
AMI has advised firms that, in order to hit the TCF deadline, a TCF review should have taken place with results collated, action points compiled and senior management having empowered staff to deliver change where it has been identified as necessary.
Recent AMI research revealed that nearly half of all respondents said they were either at the implementation or the embedded stage. This leaves over half of members not having hit the deadline. The FSA has stated that enforcement action could be taken against those firms (and individuals) who have not bought in to the TCF initiative. The FSA are questioning and visiting firms to determine how many will hit the deadline. It will publish the results of this work in April this year.
Rob Griffiths, associate director of AMI, commented: “Recent industry research has suggested that a number of firms are either not aware of the deadline or have not reviewed their practices in line with the regulator’s TCF initiative. We would like to remind intermediary firms that the deadline does exist and action should be taken to ensure the firm meets it.
“Firms should ensure they have at least conducted a review and a gap analysis. They should document all TCF work within the firm and any ‘TCF-related’ changes that have been made to the firm’s processes following a review.
“It is vital that senior management lead the TCF project within their firms. The FSA has already warned that enforcement action could be taken against those firms who fail to hit the deadline, especially where there has been no lead from management and where TCF has been ignored. There is very little time until the deadline and there are potential consequences for firms that ignore it. Firms should act now and use the AMI factsheets and the FSA’s own information to ensure they do not put themselves in an unnecessary position.”
AMI members can access two factsheets on Treating Customers Fairly, ‘A guide to TCF’ and the ‘AMI guide to developing TCF’ which is specifically aimed at smaller firms looking to carry out a TCF review and gap analysis. Both factsheets can be downloaded from: http://www.a-m-i.org.uk/closed/cug/default.asp.
