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Compliance Monitor

Fairness in practice

“[S]ome firms are still asking what, in practical terms, we are expecting them to do,” the FSA remarks in its recent paper “Treating customers fairly [TCP] – building on progress”. Previously, in July 2004, it proposed the product life-cycle as a basis for thinking about different elements of TCP, namely: product design; marketing (including production of promotions and disclosures); the sales process, taking in any advice and information provided to consumers; staff remuneration structures; customer support and information after point of sale; complaint handling; and management information (MI). Between October 2004 and March this year the FSA undertook supervisory ‘cluster’ work to examine how more than 80 firms were reflecting TCP in their activities and to draw some lessons. It looked at several of the product cycle stages and also considered two other heads, interfaces between producers and distributors and managing strategic change.

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