Research by IMLA revealed lenders had implemented TCF programmes, with 50 per cent of respondents reporting changes to product design and lifecycle processes. However it revealed lenders believed brokers had failed to fully understand TCF.
Guy Batchelor, chairman of IMLA said lenders’ approach to TCF should be welcomed, but admitted member concerns about brokers approach to the issue. He said: “There was a feeling that TCF must be embedded into the entire supply chain to include all third party providers. Over 80 per cent of our members expressed some concerns that brokers are less than fully prepared for TCF. Given the pivotal role brokers play in interacting with customers, it is important they play a full role in delivering TCF.”
He added the industry as a whole could do more to implement TCF. “Lenders can assist brokers in getting up to speed, and we also believe there is scope for the FSA to play a greater role in communicating TCF to the intermediary community.”
Alan Lakey, senior partner at Highclere Financial Services admitted brokers remained uncertain about TCF. “The problem with TCF is that the FSA is moving from a prescriptive rulebook to a principles-based rulebook.
I am not surprised by the 80 per cent figure because if you asked 100 people to define TCF you are likely to get 50 different answers all similar but sufficiently different that some would surely fall foul of the FSA because of the subjectivity.
“Are we expected to work under a regime that is able to claim a rule breach when it suits because not only the goalposts, but the entire pitch, has been moved? It’s no real surprise that we’re all confused.”
