Treating Customers Fairly (TFC)

The FSA's TCF initiative raises its head in virtually every project we conduct.

The inappropriate selling of Payment Protection Insurance (PPI) where customers would not be entitled to some of the benefit is one such area. Similarly, the recommendation of Critical Illness Cover (CIC) where the customer has a need for income in the event of long-term disability rather than a lump sum on diagnosis on specific conditions is another.

In the investment arena, it seems to us that wrap platforms could easily provide appropriate management information, as required by the FSA, that would marry appropriate customer agreements with actual delivery.

For example, the customer agreement may state that a written review with appropriate recommendations be issued quarterly. The platform could produce a report demonstrating that this had been carried out. This could extend to areas such as rebalancing, performance against benchmarks, charges and so on.

We are anxious to know what specific concerns providers and distributors have in this area so that we can conduct an appropriate detailed study.

Please email.

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