For many brokers the real challenge is the principles-based approach, which fails to give unambiguous guidelines and can, therefore, understandably lead to different approaches being taken for individual clients. The difficulty of this approach is the capture and reporting of information in a way that shows a disciplined approach, but applied in a bespoke manner.
Crystal is advising that brokers talk to their technology providers to ensure that they have appropriate functionality in place in order to meet the regulatory needs of TCF. This is about how the whole technology solution can help and not just about adding a few management reports. It also includes comprehensive fact finding, compliance rules engines and comprehensive rule driven suitability documents.
Patrick Shuker, director at Crystal, said: “TCF is an issue that causes considerable angst for many brokers as they are applying best practice but often have difficulty demonstrating this. By the December deadline we urge brokers to have spoken with their point-of-sale providers to ensure that the systems that they use not only provide compliant sales, but can produce the metrics to prove this.”
