It is now more than two years since the FSA introduced ‘Treating Customers Fairly’ (TCF). Countless papers and speeches have been delivered on the subject, and numerous training seminars have been organised. The trade press and trade bodies have been heavily engaged in arguing the merits of TCF. It therefore comes as somewhat of a surprise that some networks and their appointed representatives (ARs) have little awareness of what TCF means. Others believe they already treat their customers fairly.
The consequences of TCF denial will be harsh. Having put back its original deadline to 31 March 2007, the FSA is in no mood to accept further failings.
There is still time to take action even at this late stage. Smaller firms may well be able to get their TCF into shape before the end of March. For networks it may be more difficult because they have all their ARs to educate, new processes to introduce and management information systems to enhance. All of this takes time and commitment. With the market beginning to awake from its Winter slumber, the development of new business may be a much more urgent priority for ARs than TCF. The network will have its work cut out.
Those firms that have developed their approach to TCF, and are now at implementation stages, can breathe a sigh of relief. But there is no time to be smug. TCF does not end at 31 March; it is just the beginning.