Risk assessment Firms need to review all aspects of their business and organisational structures to ensure that they identify risks that may have an impact on their ability to treat customers fairly. Areas of risk might be: conflicts of interest – see section 6, Chapter 2. control over appointed representatives; use of third parties in the sales process; and sales documentation. Management information You need to determine what TCF means for your business, decide what you need to deliver this and ensure that you have the management controls and information in place to monitor that you are delivering this. Special Topics Template 1 which can be found at the end of this section is an example of areas you need to consider when reviewing TCF and actions that you would need to take. 1.2.2 Treating Customers Fairly Self Assessment Tool To help small firms assess whether they are treating customers fairly, the FCA has developed the following TCF self assessment tool. This tool asks the firm a set of questions relating to organisational structure, the sales process and after sales care of customers. By answering the following questions a firm should be able to identify the areas that they need to focus on to ensure that they are treating customers fairly. Management responsibilities, strategy & reporting How have you included TCF into the way you run your business and your firm’s values? How do you assess whether you are treating your customers fairly and how is this reported to management? What gaps are there against TCF and how are these being filled? What changes could you make to your organisational structure, or to services/products offered, to support TCF? How are you engaging, motivating and training all your staff on TCF? How does your firm’s management indicate their support of TCF? How is the requirement to treat customers fairly included in performance measures, objective setting and rewards for staff? How does your firm’s record keeping enable you to demonstrate whether you have met TCF obligations? How is that information shared with others in your firm?
Risk assessment Firms need to review all aspects of their business and organisational structures to ensure that they identify risks that may have an impact on their ability to treat customers fairly. Areas of risk might be: conflicts of interest – see section 6, Chapter 2. control over appointed representatives; use of third parties in the sales process; and sales documentation. Management information You need to determine what TCF means for your business, decide what you need to deliver this and ensure that you have the management controls and information in place to monitor that you are delivering this. Special Topics Template 1 which can be found at the end of this section is an example of areas you need to consider when reviewing TCF and actions that you would need to take. 1.2.2 Treating Customers Fairly Self Assessment Tool To help small firms assess whether they are treating customers fairly, the FCA has developed the following TCF self assessment tool. This tool asks the firm a set of questions relating to organisational structure, the sales process and after sales care of customers. By answering the following questions a firm should be able to identify the areas that they need to focus on to ensure that they are treating customers fairly. Management responsibilities, strategy & reporting How have you included TCF into the way you run your business and your firm’s values? How do you assess whether you are treating your customers fairly and how is this reported to management? What gaps are there against TCF and how are these being filled? What changes could you make to your organisational structure, or to services/products offered, to support TCF? How are you engaging, motivating and training all your staff on TCF? How does your firm’s management indicate their support of TCF? How is the requirement to treat customers fairly included in performance measures, objective setting and rewards for staff? How does your firm’s record keeping enable you to demonstrate whether you have met TCF obligations? How is that information shared with others in your firm?