Taking the FSA’s six consumer outcomes for TCF as a starting point, Home Buyer has identified nine specific areas of activity where delivery of TCF needs to be embedded as an integral part of the activities carried out by mortgage and general insurance (MGI) firms, and where effective controls must be established to ensure ongoing compliance.
These areas are: promotions; advice and sales process; client contact (sale and post sale); checking customer understanding; complaint handling; staff TCF awareness and training; management information; risk assessment; and product understanding.
The majority of these functions are already available within the Home Buyer System to ensure TCF, but some areas have been boosted to ensure total end-to-end TCF, especially in the key matter of establishing effective systems and controls. This has resulted in a new system being written to manage promotions, a complaints handling process, after sales care and all communications with sales staff over issues relating to TCF.
Richard Angliss, managing director of Home Buyer Systems, commented: “We are all now realising that principles-based regulation, and in particular TCF, means an evolving landscape in which all the players must constantly monitor that their business practices continue to align with the FSA’s principles. We are in in constant dialogue with Home Buyer users and their feedback has proved invaluable in enabling us to make continuous improvements in the system, up to and beyond the FSA’s deadline for TCF to be embedded in all regulated firms.”
