• Doing business with the FSA
  • Being regulated
    • Treating customers fairly
      • Management information
        • Outcome 1 examples
        • Outcome 2 examples
        • Outcome 3 examples
        • Outcome 4 examples
        • Outcome 5 examples
        • Outcome 6 examples

What we are asking of firms

We have put in place two deadlines to focus firms on having managment information (i.e. evidence) to demonstrate to themselves that they are treating their customers fairly.

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Developing and using TCF MI

We expect firms to have considered how TCF applies to them and to be developing appropriate mechanisms so that they are able to determine if they are treating their customers fairly.

A suitable approach may be to:

• Consider how the six TCF Outcomes apply to the firm. This may fit in with an existing customer vision or approach that the firm has adopted;
• Assess business activities to identify risks to consumers that are relevant to each TCF Outcome. For example, the customer buys the wrong product or they receive poor service or performance; and
• Determine appropriate measures for each TCF Outcome and related risks and establish whether evidence to measure the effectiveness is already available. If not, they may wish to establish options to create this evidence or seek alternative measures.

It may be equally valid for a firm to develop its own perspective on what TCF means and to develop appropriate measures and monitoring. In these cases we will still expect the firm to be able to evidence how their approach delivers the principle of treating customers fairly.

A second critical aspect of evidencing fair treatment is the governance and monitoring that takes place. This should demonstrate:

• Commitment and accountability from senior management where they review and ensure that appropriate action is taken over any issues identified in the MI;
• Robust, appropriate MI and effective analysis that includes qualitative insights not just quantitative data; and
• Processes in place to monitor the MI and to enable the right people to take action and to understand the impact of those actions.

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Further help

Further help is available in our 2006 Cluster report on MI and our 2007 'Treating customers fairly – guide to management information' [PDF] which are designed to help firms develop MI to demonstrate that they are treating their customers fairly. The guide provides hints and tips on gathering and using MI, including examples of good and poor practice and illustrations that we have devised to help firms understand the use of MI in the context of the TCF initiative.

Small firms should see the TCF section on the small firms pages which includes specific self-assessment tools on MI.

Examples

Follow the links to review examples from our work with firms on how they are measuring progress against the six TCF Outcomes and our commentary on these examples. These are real examples and are illustrative rather than best practice. They are designed to help firms think through their own MI challenges and they complement the existing range of materials we have already provided.

• Outcome 1 - Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture
• Outcome 2 - Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly
• Outcome 3 - Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
• Outcome 4 - Here customers receive advice, the advice is suitable and takes account of their circumstances
• Outcome 5 - Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect
• Outcome 6 - Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint

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