Treating Customers Fairly TCF Policy Template

Posted on by Know Your Compliance

 

TCF Principles & Objectives

The FCA has 3 main statutory operational objectives, with each covering the related aims: –

Protecting Consumers

  • Ensure customers are treated in a way that is appropriate for their level of financial knowledge and understanding
  • Be more outward looking, by engaging more with consumers and understanding more about their concerns and behaviour
  • Set clear expectations for firms and be clear about what firms can expect from us
  • Intervene early to tackle potential risks to consumers before they take shape
  • Be tougher and bolder, following a strategy of credible deterrence, using new powers of intervention and enforcement.

Market Integrity

  • The soundness, stability and resilience of the financial markets
  • The transparency of the price information process in those markets
  • Combating market abuse
  • The orderly operation of the financial markets
  • Reducing financial crime in the UK financial system

Promoting Effective Competition

  • To promote effective competition in the interests of consumers in the markets we regulate
  • To promote effective competition when addressing our consumer protection or market integrity objectives

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TCF Procedure Template

The standard areas within a TCF Procedure document include: –

  • Policy – this can be a separate document, or a summary of the related policy can be included in the procedures. It reminds those following the procedures why they are in place and what the objectives are.
  • Purpose – what are these procedures aiming to do?
  • Scope – what areas of the organisation are affected and/or governed by the procedures.
  • Definitions – if there are any words, phrases or acronyms used in this document that could cause confusion or misunderstanding, you should define them and provide a simple explanation.
  • Procedure – the actual steps and activities used to complete the task or area associated with this document. All steps should be included, no matter how basic as procedures are also used in the auditing process to ensure that no steps are missed, or gaps identified.
  • Auditing & Monitoring – although auditing & monitoring all your procedures and business activities will be included in their own documents, each procedure should contain a summary of how you audit and monitor the processes.
  • Responsibilities – who is responsible for following the procedures set out in this document and for updating and maintaining of the document.

6 TCF Outcomes

The 6 TCF outcomes detail what the FCA are trying to achieve for consumers. They are used for guiding regulatory decisions and actions and remain at the core of what the FCA expects of firms.

  • Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
  • Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
  • Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  • Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
  • Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
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