Secondary

Think TCF – Part Seven

In this, the final article on this topic, we share some practical ideas for you to consider. I need to express my sincere appreciation to Billy Seyffert for the use of his presentations as background to the series.

  1. You and your business must live the principles. Simply having a TCF policy document will not be enough. The outcomes for your clients will determine whether you have succeeded in this regard.
  2. A documented policy, including a mission statement, must be adopted at the appropriate level as the blueprint of how you will ensure satisfactory outcomes.
  3. Your staff needs to be trained on the practical application of your TCF policy, and be made aware of their respective responsibilities in this regard.
  4. You would possibly need to review current and future employment terms to provide for your expectations and their responsibilities regarding TCF.
  5. It is also important to review current procedures, including your complaints management policy, to ensure that it is aligned with the six outcomes of TCF. The recently published discussion document on complaints handling, discussed above, will be a more than handy guide.
  6. Larger FSPs should consider an implementation plan, and document progress as proof of living the principles contained in TCF.
  7. Finally, a review of your Risk Management Plan is required to ensure that you address possible issues that may arise from unfair treatment of clients.

Merely complying with the letter of the Act is no longer all that is required. Your clients have to experience your compliance in a practical manner. The Regulator’s decision to first focus on after-sales service (discussed above) may also be a good indication of where you should start applying TCF in your practice.

TCF – Guidance for small FSPs/ Independent Financial Advisors (IFAs) and

TCF – Guidance for Asset Managers.

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