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So this is a good time for wise firms to take stock and use the summer lull to review two things. First, are the basics in place that mean an FSA visit or mystery shop will go as smoothly as you wish? Second, are you where you should be on the Treating Customers Fairly implementation timetable? The FSA will be conducting a quality of advice mystery shopping exercise in the mortgage market later this year so now is the time for firms to check that:
The advice process is documented and all advisers are conversant with this.
Disclosure documentation is up-to-date and accurate, and can be explained by advisers.
The firm’s charges are clear to customers and advisers.
Fact-finding is complete and takes place before applications begin.
Customers’ attitudes to debt and their overall debt levels are investigated and play a part in recommendations.
Suitability of any recommendation can be clearly seen from comprehensive records.
Where insurance products are discussed, this is done fully and in accordance with the firm’s permissions and the FSA factsheet on mortgage payment protection insurance.
Firms should also check their remuneration structures are fair to their customers and not simply based on new business volumes.
And this takes us neatly on to TCF. It is almost inconceivable that anyone in the industry does not to know about TCF and its importance by now.
Summer is the ideal time to check on your progress in this regard. Here’s a tip – email everyone your firm and ask them what TCF stands for and to supply you with one example of the way they are implementing it. You’ll be able to judge the progress your firm is making by the responses you get.
The FSA has just published more information on TCF and the AMI website is practically groaning under the weight of information that firms can download to help them better understand and implement TCF in their businesses. Recent AMI newsletters have also discussed this theme.
One thing is for sure, the regulator’s attitude to firms that are not implementing TCF will be a great deal hotter than the water lapping against the beach on your holiday. Make use of the summer time to ensure your living is easy well into next year.