What you need to do to implement TCF
You are required to take an objective look at the way you do business. Small firms do not have to have a documented strategy or detailed files showing how you deliver on TCF. There is no requirement to record what you checked, but you may wish to keep a record of the main decisions made in order to communicate what you looked at and be clear about any areas that need addressing.
You should have appropriate processes in place to enable you to satisfy yourselves that you are treating your customers fairly, for example through the use of records (management information) on advice given, products sold, and complaints.
You should be able to describe how TCF fits into your business and how behaviour within your firm takes account of the needs, acceptance of risk, level of understanding and rights of your customers.
By now, you should have reviewed where there might be 'gaps' between how you should be treating customers fairly and what is happening in practice. The types of things you should focus on will depend on the nature of your business.
To help you make your assessment, we have developed a set of questions relating to your firm's structure, the sales process and the after-sales care of customers. The TCF self assessment tool is not a checklist, but is designed to prompt you on some of the areas on which you should focus to be satisfied you are treating your customers fairly.
TCF self assessment tool [PDF]
Management information
TCF and financial promotions
Unfair contract terms
We expected all firms to have implemented TCF in a substantial part of their business by the end of March 2007. This meant that you should have identified the key risk areas to the delivery of the consumer outcomes (the gaps) and have taken action to address those gaps.
You should undertake a follow-up review at least annually or whenever there is a significant change in your business such as selling new products or offering new services.
