Treating Customers Fairly – wholesale firms, management information and other animals

The deadline for embedding treating customers fairly within organizations is the end of this year. At the same time, Sarah Wilson who heads up the TCF team at the FSA has commented that the project applies equally to some wholesale firms. Regulated businesses still glaze over, grizzle and panic when anyone mentions the management information requirements. The FSA has just reported that only 13% of relationship managed firms met the March deadline for being able to show using management information whether they are achieving the six TCF outcomes. This all seemed like a good reason to bring in regular contributor, Adam Samuel , to cast some light beyond the shadows.

In the early days of Treating Customers Fairly, it was difficult to be opposed to the idea and what the regulator was trying to achieve. One could see the whole idea as an alternative device used by the FSA to improve the lamentable standards of compliance in customer-facing parts of many financial services businesses. Equally, the Equitable Life debacle and the disappearance of “policyholders’ reasonable expectations” from UK financial services legislation pointed up the need to have a regulatory device to ensure that firms honoured promises or met customers’ reasonable expectations. Although developments in this last area have been piecemeal and often incoherent, it has been a salutary exercise for some firms to learn how far short they have been falling in seeking to honour promises to customers.