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Make it happen
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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