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A look at the FSA's 'Treating Customers Fairly' initiative and how we've embedded it into our business...

The Financial Service Authority's 'Treating Customers Fairly' initiative is a requirement on all FSA regulated firms to embrace and adopt throughout their practices to help ensure customers receive a fair deal.

Here we delve deeper into the Treating Customers Fairly initiative and its purpose, together with how Shire Direct has embraced and embedded this initiative throughout all we do.

A closer look at the Treating Customers Fairly initiative and it's purpose

The requirement on firms to treat their customers fairly is not new: It is a part of the Financial Service Authority's (FSA) existing regulatory requirements and is firmly rooted in their Principles. Principle 6 states 'a firm must pay due regard to the interest of its customers and treat them fairly'.

The TCF initiative is central to the delivery of the FSA's overall work in the retail market and aims to ensure an efficient and effective market which helps customers obtain a fair deal by focusing on:

  • Capable and confident customers;
  • Simple and understandable information, for customers, and used by, customers;
  • Well managed and adequately capitalised firms who treat their customers fairly;
  • Risk-based and proportionate regulation.

Treating Customers Fairly (TCF) is not just about customer satisfaction, but must cover every aspect of the business including:

  • Training of staff;
  • The provision of clear and easy to understand information for customers;
  • Ensuring the customer gets the right advice / product;
  • Meeting customers' expectations;
  • Putting things right if they go wrong, and understanding why something went wrong and to stop it happening to other customers;
  • Not taking advantage of your customer.

Implementing and embedding the TCF initiative

The FSA have developed six consumer outcomes that explain what they expect the TCF initiative to achieve. These outcomes will be considered when implementing and embedding TCF and in particular when assessing whether the changes the firm is implementing has any impact.

  • Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture;

  • 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;

  • Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale;

  • Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances;

  • Outcome 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;

  • 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.

How Shire Direct has embraced and embedded the Treating Customers Fairly initiative throughout all we do

The Directors and Senior Management of Shire Direct Mortgages are committed to ensuring that the Financial Service Authority's principle of Treating Customers Fairly (or TCF for short) is applied in all areas of our day-to-day business activities.

In adopting the TCF principle, we recognise that fair treatment of our customers is about adding value to the service we offer by aiming to:

  • Protect the interests of our customers at each stage of the product life cycle, from promotion right through to after sales service.

  • Meet as best we can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing our service to identify areas for improvement.

In practical terms for the different areas of our business this means:

  • Ensuring that promotional material is clear, compliant, jargon-free and appropriately targeted

  • Ensuring that all sales staff (both on and off-site) have thorough training on all products they advise on or sell, understand who they are and aren't suitable for, and are encouraged to challenge product providers where they spot inconsistencies, ambiguities or potential unfairness in the product literature or product features.

  • Operating sales remuneration systems that assure fairness to the customer as well as customer satisfaction, rather than only rewarding sales volumes.

  • Finding ways to encourage non-sales staff to implement TCF in their day-to-day business activities.

  • Keeping detailed records of customer instructions and profile/attitude to risk, and of the advice and options given before, during and after a sale - to help ensure we treat customers fairly, and can deal with any complaints that may arise swiftly and fairly.

  • Encouraging after sales contact with clients where appropriate, to correct or improve on the service already offered.

  • Ensuring that customer complaints are assessed fairly, promptly and impartially, and in line with FSA deadlines and rules.

  • Encouraging staff to recommend improvements to service following customer complaints - and monitoring the outcome.

  • Ensuring that sales staff are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers.

  • Offering regular training in the principle of TCF at all levels of the business.

  • Regular monitoring and reporting on all of the above TCF activities as part of the company's monthly statistic and Management Information, in order to assess TCF performance across the business and recommend changes where appropriate.

  • Ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way.

Shire Direct Mortgages takes the Treating Customers Fairly initiative very seriously and have ensured that time has been taken to identify any gaps within the business and that changes have taken place to implement the new standards and then to embed this continually into its management structure and business.

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Shire Direct and Shire Direct Mortgages are trading styles of Shire Processing Centre Limited which is
Authorised and regulated by the Financial Services Authority in respect of regulated mortgage products and general insurances.
Registered No: 302389. Commercial funding and Secured Loans are not regulated by the FSA.
Licensed Credit Brokers. Consumer Credit Licence Number: 349999.

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