Briault, speaking at a TCF conference held in London this week, said he had been encouraged by businesses identifying areas where objectives are not being met and responding to these needs. He said TCF needs to be ‘embedded into the culture of a firm at all levels so that over time it becomes business as usual’.
He went on to praise the initiatives taken by trade associations to address any TCF concerns and how their members could further improve the service they offered clients, before revealing his thoughts on plans for the future of TCF.
He said: “We have now reached the stage of the TCF process where we are building TCF into Arrow, our core assessment and mitigation process. Supervisors will be looking at the approach that a firm has taken to Treating Customers Fairly including both the initial ‘gap analysis’ and subsequent actions to address any resulting issues.”
He also confirmed changes to legislation regarding management information, remuneration, complaint-handling and closing with-profits funds are to be published on the FSA website.
However, Harry Katz, principal of Norwest Consultants, was stunned at the speed of change within the implementation of TCF and argued the rules did not relate enough to the industry.
He said: “All TCF boils down to is a safety net so if anything slips through they can corner it with these guidelines. It’s pretty much a way of making rules without actually making rules – a ‘cover-your-arse’ strategy. Not only has TCF not bedded in properly but with adjustments constantly being made it is leaving many people confused.”