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Treating Customers Fairly
Steve Carruthers, RBS Intermediary Partners and Frank Eve, Frank Eve Consulting




The RBS Intermediary Roadshow                                       September 9, 2008
The RBS Intermediary Roadshow




            Making a difference to your customer




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The RBS Intermediary Roadshow


Welcome & session objectives



  • What is TCF & its part in the
    mortgage sector?


  • The lender view


  • The intermediary view


  • Help available


  • Question & Answer / Discussion



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The RBS Intermediary Roadshow


What is TCF?



   Sarah Wilson, Director for Treating Customers
     Fairly, FSA:
   “TCF is a principles based initiative which
     challenges firms operating in retail financial
     markets collectively to make a step change in
     their treatment of customers. We are asking
     firms to focus on outcomes rather than process
     and detailed rules, and have defined six
     consumer outcomes against which firms should
     measure progress.”

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The RBS Intermediary Roadshow


The 6 TCF Consumer Outcomes



 1. Consumers can be confident they are dealing with
    firms where the fair treatment of customers is
    central to the corporate culture
 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
 3. Consumers are provided with clear information
    and are kept appropriately informed before, during
    and after the point of sale
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The RBS Intermediary Roadshow


The 6 TCF Consumer Outcomes…….(cont.)



  4. Where consumers receive advice, the advice is
     suitable and takes account of their circumstances
  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
  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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The RBS Intermediary Roadshow


How does TCF apply to mortgage sector firms?



  Key areas for mortgages are:


  • Product design


  • Disclosure


  • Remuneration strategy




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The RBS Intermediary Roadshow


TCF – the lender view



   • TCF is not new – evidencing existing practices
   • Not about being „nice‟ to or creating satisfied customers
   • FSA will not arbitrate over what products consumers want or are sold
   • Does not absolve consumers of responsibility
   • Not about collecting large amounts of MI
   • By 1st December 2008 we will demonstrate that:
         – TCF is being integrated into our business culture
         – Appropriate MI and measures are in place to test whether we are treating
           customers fairly & delivering the 6 outcomes
         – There are processes in place to monitor the MI to enable the right people
           to take action



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The RBS Intermediary Roadshow


TCF – the lender view



  • Lenders & distributors will not „police‟
    each other


  • A partnership approach – share key
    data/MI


  • Keep it simple – help each other to
    evidence


  • An evolving & ongoing programme


  • We do „walk the talk‟ as a key priority

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The RBS Intermediary Roadshow


TCF for the Intermediary




                        FRANK EVE
                        Chairman
                        TCF Lender Forum




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The RBS Intermediary Roadshow


TCF for the Intermediary


• Specifically TCF aims to:
           – help customers fully understand the features,
             benefits, risks and costs of the financial products
             they buy
           – minimise the sale of unsuitable products by
             encouraging best practice before, during and after a
             sale
• The FSA „Conduct of Business Rules‟ support TCF
• To satisfy FSA requirements extra steps required to show
  how you‟re implementing TCF throughout your business.


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The RBS Intermediary Roadshow


TCF for the Intermediary


• FSA doesn‟t lay down any standard way in which TCF
  should be assessed and implemented, but highlights key
  areas within 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


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The RBS Intermediary Roadshow


TCF for the Intermediary


• In practice this means identifying potential gaps (Gap Analysis)
  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
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The RBS Intermediary Roadshow


TCF for the Intermediary


• www.tcfinfo.co.uk
     – Free practical, user-friendly, online resource
     – Plain English guides, tips and tools and checklists on all
       the areas previously outline
     – You can download any of the material for own-branding
       and/or staff training – for free
     – Funded by major mortgage lenders & supported by CML




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The RBS Intermediary Roadshow




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The RBS Intermediary Roadshow


TCF for the Intermediary


• Example checklist can be
  used for Gap Analysis and
  auditing
• Will email attendees to offer
  free registration which
  entitles them to receive free
  e-newsletters and updates
  on relevant TCF matters




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The RBS Intermediary Roadshow


Summary



                                                     Treating Customers Fairly
                                                    Lenders and Intermediaries
                                                                                                                       There will be areas of overlap,
            “A customer's experience should not be                    Our primary responsibility is to                 however the onus is on us to
            affected by whether a product or service is               ensure the customer has the                      determine how to ensure we
            provided and distributed by a single                      information they require, and the                provide information that is clear,
            institution or by two or more institutions.”              product that best suits them.                    sufficient, and appropriate for the
                                                                                                                       channel.




                                LENDERS                                  CUSTOMERS                            INTERMEDIARIES
                                                                                                      Our brokers have the responsibility to:
                        The information provided to brokers
                        is sufficient, clear, and appropriate.
                                                                                                      Ensure they have sufficient information
                                                                                                      about our products and understand it, or
                        The channel selected is appropriate for
                                                                                                      ask for further information if they don‟t.
                        the product and market
                                                                                                      Fully consider customer needs and
                        It is clear where information is for brokers
                                                                                                      circumstances
                        only, and where it can be shared with
                        customers
                                                                                                      Ensure the post sales experience
                                                                                 TCF                  matches the expectation they give the
                        We monitor the results and act on
                                                                                                      customer
                        concerns


                              Lenders and intermediaries are not expected to „police‟ each other – the FSA will monitor both individually


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The RBS Intermediary Roadshow


Question & Answer




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The RBS Intermediary Roadshow


TCF in practice….




                                FAIR
                                PLAY?

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The RBS Intermediary Roadshow


Is this TCF?




 • A customer goes
 into a branch of
 Acme Mortgages
 plc and applies for
 a mortgage but
 computer says NO!


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The RBS Intermediary Roadshow


Is this TCF?




                                • Acme plc
                                  Mortgage
                                  Business has
                                  the highest level
                                  of arrangement
                                  fees in the
                                  industry

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The RBS Intermediary Roadshow


Question & Answer




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