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TCF Monitoring

From December 2008 TCF became ‘business as usual’ – this means that all firms selling mortgages must be able to demonstrate to the FSA that they are consistently treating customers fairly.

TCF ‘business as usual’ – what it means for you

Your firm must:

  • be able to demonstrate that the business owner (in small firms and one-man-bands) or senior management (in larger firms):
    • understands what the fair treatment of customers means
    • understands where/how they expect staff to achieve this at all times
    • ensures that errors (of which there should be relatively few) are promptly corrected and learnt from
  • be appropriately and accurately measuring performance against all customer fairness issues that are materially relevant to their business and be acting on the results
  • be demonstrating through those measures that they are delivering fair outcomes
  • have no serious failings – whether seen through management information (MI) or other failings (including regulatory) already known to and publicised by the FSA

To monitor TCF, the FSA is carrying out face-to-face and telephone mini-assessments with small firms and, in the case of larger firms, providing feedback following ARROW assessments. By way of general support it continues to offer TCF regional workshops, and additional guides and case studies on its website.

The FSA will continue to take enforcement action against firms where there has been actual or potential detriment to customers as a result their practices – and in particular where a firm fails to change its practices following warnings.

Follow the links to find out more.


Improved TCF guidance from the FSA, contact centre help, regular surgeries and more

FSA ‘at a glance’ chart showing key drivers and indicators of TCF implementation

Overview of TCF failings that have resulted in enforcement action within the mortgage industry