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TCF should flow through a business

For my company, TCF starts with product design which ensures fairness throughout the business and all brokers should be thinking along the same lines, says Drew Wotherspoon

As the leader in last week’s Mortgage Strategy mentions, the Financial Services Authority’s deadline for brokers to im-plement the Treating Customers Fairly initiative is just a few weeks away. At the end of March, the FSA expects TCF to be pretty dominant in all companies’ thinking and for senior management to be aware of how they treat their customers.

For John Charcol, the deadline has not presented any problems as we have been consistently working towards implementing the initiative across all areas of our business for some time. We have had an open dialogue with the FSA which has proved worthwhile in getting the feedback we need at all stages of implementation.

We see TCF as a ‘business as usual’ activity for our company as it should be for all brokers, particularly independent ones. In fact, independent brokers are in the enviable position of having a solid TCF proposition already.

The definition of a good independent broker is that it does the best job it can for its clients – something banks and building societies cannot take for granted.

But TCF is about so much more than frontline communications with customers. Championing the principles of TCF throughout a business is important and something we have been particularly focussed on.

Our TCF project is led by our chief executive and the rest of our executive board who, between them, have responsibility for the workforce and are in prime position to embed this culture throughout.

We are clear that compliance does not own TCF, it merely supports the executive board when and where it is needed. We find this is a sensible way to ensure the desired results are achieved.

It’s not just our interactions with customers that count. Starting at the beginning of the process – with product des-ign – ensures a natural flow of fairness throughout a business. We welcome any support we can get from lenders, and indeed discussion about the progress they are making on TCF.

Helping each other with mutually beneficial initiatives that create innovative and fair products which also meet the high standards dictated by natural competition in the marketplace is of paramount importance.

It will be interesting to see how the market does after the deadline. For example, there are still a plethora of advertisements in the press which are nowhere close to being compliant or fair.

Mortgage Strategy reported last week that the Association of Mortgage Intermediaries is fairly pessimistic about its members’ readiness, with not even half being at the implementation stage. You have to admire some people’s positive outlook on life though – 75% of AMI members say they will be ready on time.

It seems that a month is not enough time to get ready for such a fundamental change. With the FSA planning to come down hard on those who are not ready, the next few months should be interesting.


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