FSA Deadline for implementation March 2007
Key observations:
Responsibility of Management to make it happen: part of corporate culture.
That the products and services that we promote are right for the specific customer.
That the customer receives clear, fair and not misleading information about the products and services in a timely manner.
That we can demonstrate that we have taken into account the Customers circumstances.
That our standards of performance are at the level that the customer had been led to expect from us.
That customers do not face unreasonable post sale barriers should they change their mind etc.
Base line assessment where were we in Oct 2005?
What are we doing differently now to demonstrate TCF compliance?
How are we measuring it?
Complaints levels
Referrals / sources of new business
Feedback from customers - surveys / thank you letters etc.
Peer reviews
Frequency of TCF Company wide reviews? (Annual is about right)
Supervision of staff / file reviews but do we record the feedback given?
Communications :
What involvement do staff have with TCF?
What training have we provided initially and ongoing?
What have we included in Induction training for new staff?
Do we have a TCF policy and how is this communicated?
Issues
We are in the people business if we dont look after our clients they will go elsewhere.
Marketing mix products and services provided
Conflicts of interest involvement with claims handling / profitshare?