The Financial Services Authority (FSA) have made ‘Treating Customers Fairly’ (TCF) central to their retail regulatory agenda. In simple terms this means making sure that the customers receive a fair deal. It would seem hardly necessary to define what ‘treating customers fairly’ is all about, although the six principal outcomes that the FSA seek to achieve perhaps throw the concept into sharper focus. The following is taken from the FSA website:
Outcome 1: Customers 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: Where consumers 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 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.
Our concern is that when a regulator lays down a principle that can be reduced to a 3 letter acronym then ‘TCF’ becomes a tick box exercise. At Chamberlain we firmly believe that treating customers fairly should be at the heart of any business with integrity and that it should never be reduced to a checklist, the sole function of which is simply to prove that a business has gone through the motions. We do not treat customers fairly because the regulator tells us to but because it would never occur to us that there is any other form of acceptable conduct.