• Doing business with the FSA
  • Small Firms
    • General information
      • Treating customers fairly
        • Progress against 31 March deadline
          • Examples: Investment / Financial advisers
          • Examples: General insurance intermediaries
          • Examples: Mortgage intermediaries

We set a deadline for all firms to be at least implementing TCF in a substantial part of their business by the end of March 2007. The aim of setting the deadline was to stimulate action in firms that were slow to appreciate the significance of TCF and to maintain momentum in those firms that were making progress.

We conducted a major telephone survey (659 firms) to assess progress made by small retail firms. This was supported and followed up with visits to a number of firms to verify that the assessment we had reached, based on information supplied by the firms, was correct. We concentrated the sample around the three major sectors in which small retail firms operate - investment, general insurance, and mortgage business.

The surveys focus was to assess what firms were doing on a range of important TCF issues, such as management behaviours, and how these impact, for example, on advice and complaints.

Management behaviours

Firms who have not met the 31 March deadline

All firms who participated in the survey were given direct feedback at the time about their firm's progress.

In line with our risk-based approach, our primary focus is to target those firms who pose the greatest risk to our objectives such as those where progress was particularly poor or where firms have failed to engage with TCF. We aim to visit every firm in this category by the end of June 2007.

We have provided further information about the main shortfalls identified in their sector to those firms who have engaged with TCF but whose progress was slow or of poor quality. This was to help these firms to consider whether and how these findings may be relevant to their business and whether they should be taking further action. We will be carrying out further work, including follow up visits to 10% of these firms.

Where firms are still making insufficient progress and where this gives rise to potential or actual consumer detirment, we will take appropriate action which may include enforcement action.

What about those firms not measured as part of the survey?

TCF remains a high priority and we have a number of thematic projects ongoing and new ones planned, to target firms and test whether they are delivering fair outcomes for consumers. Project work provides us with a valuable insight into how firms are managed and controlled and whether the management behaviours are right to bring about the right outcomes for consumers.

Survey – Detailed findings

Our review showed that firms who had used the material on this website, for example the self-assessment tool, made better progress than firms who had not taken advantage of the help available. Firms found the material helped them understand what TCF was trying to achieve and what they needed to do to meet the deadline, as well as build TCF into 'business as usual'.

The main issues identified from the survey were:

• insufficient monitoring of the advice being given to customers to ensure that it is suitable and meets their needs;
• inadequate complaint handling procedures, including lack of staff training on how to identify and respond to complaints; and
• lack of appropriate processes to enable each firm's management to satisfy themselves that they are treating customers fairly, for example through the use of records (management information) on advice given, products sold and complaints.

Examples of good and poor practice

We have included examples of good and poor practice for three key sectors which will explain in more detail what we found in these key areas.

• Investment / financial advisers
• General insurance intermediaries
• Mortgage intermediaries

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