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If you can answer ‘yes’ to the points on each checklist, and are confident that you have records to back up your answer then you’re probably implementing TCF.
If the answer is ‘no’ or ‘not sure’ follow the links to the related guides, tips and tools to find out what further action you could take.
You can download a copy of this checklist on the right-hand side or at the end of the page. You may find this useful for general training purposes.
You can also download an adapted version (TCF Principles Self-Audit Checklist) at the end of the page. This document has extra columns to enable you to keep a written record of ongoing TCF implementation in your business and could form part of your TCF Management Information.
- Is sales and marketing material (ads, leaflets, posters, direct mail) written using plain English?
- Are jargon terms (eg ‘ASU’ ‘Variable rate’) fully explained?
- Does the material carry the required warnings under FSA rules?
- Are you satisfied that the APR quoted is an accurate reflection of the costs of the product(s) being promoted?
- Are restrictions/exclusions/opt-ins and opt-outs associated with the mortgage being promoted easy to pick out?
- Are all the charges, including any early redemption charges, made clear?
- Does the promotional literature make clear who the product’s most suitable for?
- Is the ad/direct mail letter positioned/targeted at an appropriate audience?
- Have you tested the promotional material with a non-expert?
- Has a compliance expert checked the promotion?
- Financial promotions – ‘tips and tools’
Sales advice process
- Has product training been provided for the products you’re offering?
- Do you/the sales person fully understand the products?
- Are you clear about any customer group these products wouldn’t be suitable for?
- Have you discussed several product options with the customer or just one?
- Is your sales channel suitable for the product the client is signing up to? (eg if the product is complex, can you offer advice?)
- If providing advice, have you completed a detailed Fact Find?
- Have you established your customer’s attitude to risk as part of your Fact Find?
- Are you satisfied that your customer can afford the product now and in the foreseeable future?
- Have you given the customer the ‘Keyfacts about our mortgage service’ (IDD) document?
- Have you provided the ‘Keyfacts about this mortgage’ or ‘KFI’?
- Are the above Keyfacts documents accurate and complete?
- Have you asked the customer whether they understand the documents you’ve provided?
- Are you satisfied that the customer understands the benefits and risks of the product they’re buying and the associated costs?
- Are you satisfied that your customer agreements are clear and understood?
Client contact information (sales and after-sales)
- Do you keep a copy of all correspondence with clients?
- Could you retrieve this if asked?
- Do you keep a record of provision of Keyfacts documents?
- Do you keep a note of telephone and meeting conversations and could you retrieve these?
- Do you keep in contact with your client after you’ve sold them a product?
- Do you record the above contacts?
- Does your organisation have a dedicated complaint handling department or specialist?
- Do you log complaints by type/nature?
- Do you follow FSA turnaround standards for complaint handling?
- Do you follow FSA requirements for reporting complaints?
- Do you monitor complaints and take action if necessary to change the way you operate?
- Does senior management (where relevant) review complaint statistics?
- Do you offer staff training in complaint handling?
TCF staff training/awareness
- Is TCF written into your organisation’s stated values/aims?
- Is the TCF message affirmed/communicated to staff by senior management?
- Has your staff received information and/or training in the principle of TCF?
- Can you measure your staff’s understanding of TCF?
- Is the training/information tailored to their area of activity?
- Could you provide information to confirm the above?
- Is any element of staff remuneration in your organisation related to treating customers fairly?
- Do you have a TCF staff awards programme?
- Do you have service standards that encourage TCF?
Management information (MI)
- Does your organisation keep statistics on the following key indicators:
- Volume of sales by product type
- Volume of sales by commission type
- Offer to completion rate
- Early redemption rate on limited period products
- Volume of complaints
- Complaints by adviser/product
- Complaints by other
- Percentage of complaints upheld/not upheld
- Percentage of complaints referred to Financial Ombudsmen Service (FOS)
- All of the above by broker/adviser/appointed representative
Risk assessment of TCF non-compliance
- Do you have a process for monitoring TCF standards amongst appointed representatives off-site?
- Are you happy that you understand the product literature and/or training provided to you by lenders?
- Do you have a procedure for challenging literature/products if you find them unclear or inappropriate – or if there are points on which you are unsure?
- Could you demonstrate this if asked?
This has extra columns to enable you to keep a written record of ongoing TCF implementation in your business and could form part of your TCF Management Information.