The six TCF outcomes

The six consumer outcomes explain what the FCA  want TCF to achieve for consumers.

Fair consumer outcomes remain core to what the FCA expect of firms, the FCA will measure a businesses ability to provide consumers with the outcomes below, businesses that can’t evidence these will be subject to supervisions and potential sanctions:

  • Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture. Basically the decisions we make need to reflect the customers needs – example: We don’t choose the funder because they give us the highest commission. That does not mean we can’t choose the funder that offers the highest commission, it just means that the decision to go with that funder is based on the product and service being the best choice for the customer.
  • 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. We have to ensure that we have looked at the customer and we’re not selling them something that isn’t appropriate, this includes and marketing material we send out – example: we don’t sell Leasing to customers that want ownership and we don’t send marketing material to businesses that are on “non marketing preference lists”.
  • Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale. Just doing the job properly, keeping in touch with the customer and keeping them informed of what is happening at every stage of the deal.
  • Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances. We do not claim to give advice, but the recommendations we give can be seen as giving advice even though we have disclaimers to the contrary. example: If a customer says they want a specific product or profile, but you find from speaking to them that another product or profile is better, that is classed from an FCA perspective as advice. That’s not to say that we should not be doing it, but we should ensure that we have taken into consideration all aspects of the customer’s circumstances when switching them from one product or profile to another.
  • 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. Make sure the customer is aware of all the facts, if you fail to mention a specific feature of a product then you run the risk of not adhering to Outcome 5 – example: Minimum term lease – the customer needs to understand that the rental “may” continue after the primary period.
  • 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. In the event that the customer isn’t happy with a service, the product or provider, we have to get involved and help them as much as possible. Complaints should be reported immediately, so that we can respond in line with the Company Complaints Policy.

Assessing and implementing TCF

The FCA doesn’t lay down any standard way in which TCF should be assessed and implemented, but it has highlighted key areas within the product life cycle where it’s a good idea to have extra checks in place. These include

  • Product design
  • Financial promotion/marketing practices
  • The sales process
  • Information and customer support after the point of sale
  • Complaint handling

In practice this means identifying potential gaps in TCF practice and developing procedures and checks to plug these in the following areas

 

  • Staff training/awareness of TCF
  • Sales and marketing material
  • Product understanding
  • Advice and sales process
  • Fact find and flow of information to the client (including after-sales)
  • Complaint handling
  • Remuneration/incentives
  • Risk assessment of TCF non-compliance
  • Record keeping and Management Information

Training & Competence