Treating Customers Fairly self-assessment pilot – kudos and concerns
As part of the roll out of its Treating Customers Fairly (TCF) programme, the Financial Services Board (FSB) has piloted a self assessment tool that, once finalised, will enable regulated firms to gauge their success in achieving the six TCF fairness outcomes. The results of the pilot were presented at the recent 9th Cape Conference of the Compliance Institute Southern Africa.
TCF is a programme for regulating the market conduct of financial services firms, and ensuring that customers are treated fairly. The FSB has developed a roadmap for its implementation, which will include recommendations for new legislation to enforce it.
The aim of the pilot was to obtain industry feedback on the usefulness of the draft TCF self-assessment tool. Twenty firms participated, but as most of them were large to medium sized groups with multiple regulated entities, the FSB received more than 50 completed questionnaires, covering more than 250 FSB licensed entities.
“Overall the feedback was detailed, comprehensive, and most participants took the process seriously,” said Leanne Jackson, head of Treating Customers Fairly at the FSB. The pilot also resulted in in-depth follow up meetings between the FSB and participants, further enriching the feedback.
Several examples of good practice emerged from the pilot, and these have been included in the FSB’s report, which is available on its website. “We aren’t necessarily recommending those practices, however, as we haven’t verified or checked them.”
She said some firms aren’t doing much to embed TCF in their organisations because the legislation hasn’t been finalised. But Jackson said that although the FSB would be providing ongoing guidance, there was no need to wait for that before starting their TCF implementation plans, as the six outcomes were at the heart of the programme and firms should be making progress on delivering on them.
Some companies are still asking the FSB how to define fairness, for example, or trying to define it for themselves, but the FSB has purposely not defined it. “We’ve listed the six fairness outcomes and those will be the litmus test for compliance, not a theoretical definition of fairness,” she said.
Of particular concern was a general lack of strategic focus on TCF. Critically, many companies with a customer service strategy took that to be their TCF strategy. According to Jackson, however, TCF needs to be thought through right across a group’s strategy as it could impact on profitability, marketing, business processes, product design, human resources, distribution and more.
“Firms don’t generally foresee substantial changes to their strategies and operations. Rather, they predict a need to ‘tweak’ existing processes to more visibly and ‘formally’ demonstrate existing commitments to TCF. We wonder if that’s actually realistic.”
She said companies tended to think that TCF was implicit in the way they operate, but it’s not something they’ve thought about formally. But they’ll need to demonstrate delivery of the TCF outcomes to the FSB, which will require some degree of formalisation.
She also said there was confusion between customer satisfaction and fair treatment of customers. “They may overlap, but they’re not the same thing.”
Julie Methven, CEO of the Compliance Institute of Southern Africa, said that TCF was a good example of a shift from purely rules-based regulations to principles-based regulations. “Compliance officers can no longer simply adopt a tick-box approach. Instead, they have to apply a host of principles and guidelines to their businesses and support management in ensuring compliance accordingly.”
Claire Densham Communications
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