The deadline was issued in last summer’s FSA publication Treating Customers Fairly – towards fair outcomes for consumers. In it, the FSA said by March 31 2007 it expected all firms to have “implemented TCF in a significant part of their businesses”.
The FSA has said a firm is at the “implementation” phase when it is developing plans and processes, allocating TCF resources and responsibilities and creating capability among its staff.
Implementation is the third stage in the FSA’s four-stage TCF process for firms to work through, starting with ‘Awareness’, moving through ‘Strategy and Planning’ to ‘Implementation’, before ending up with TCF ‘Embedded’ within the business.
AMI has advised firms that, in order to hit the TCF deadline, a TCF review should have taken place, with results collated, action points compiled and senior management having empowered staff to deliver change where necessary.
Recent AMI research revealed nearly half of all respondents said they were either at the implementation or the embedded stage. But this leaves over half of the its members missing the deadline. The FSA has said enforcement action could be taken against firms or individuals which have not done enough in terms of the TCF initiative. It is also questioning and visiting firms to determine how many will hit the deadline and will publish the results of this work next month.
Rob Griffiths, associate director of AMI, says recent industry research suggests a number of firms are either not aware of the deadline or have not reviewed their practices in line with the regulator’s TCF initiative.
He says: “Firms should ensure they have at least conducted a review and a gap analysis. They should document all TCF work within the firm and any ‘TCF-related’ changes that have been made to the firm’s processes following a review.
“It is vital that senior management lead the TCF project within their firms. The FSA has already warned that enforcement action could be taken against those firms which fail to hit the deadline, especially where there has been no lead from management and where TCF has been ignored.
“There is little time until the deadline and there are potential consequences for firms that ignore it. Firms should act now and use the AMI factsheets and the FSA’s information to ensure they do not put themselves in an unnecessary position.”