Example TCF training plan
Having a TCF training plan in place will help ensure that your staff understand and support TCF values, and are kept updated on new developments.
The level and nature of training needed will depend on the size of your business. In some cases it may be incorporated into an existing customer care regime (and not necessarily be called ‘TCF’), in others it will be a separate initiative. The format doesn’t matter, as long as the outcome is the same.
If your firm is just setting up and isn't sure where to start, the steps below may help. The level and nature of training needed will depend on the size of your business.If your firm is established, the steps below offer a useful reminder of how your staff training should be progressing.
1. Create a general introduction to TCF for all staff
Depending on the size of your firm this could take the form of a one-to-one talk, a small workshop or a more formal presentation. Key elements could include:
- A summary of the TCF principle and how it applies to the different stages of the product life cycle. For key points to include see What is TCF?
- Your company TCF objectives statement
- What TCF means for different areas of activity relevant to your particular business – offering high level and ‘quick to grasp’ examples for each (see below).
- For established firms, an overview of your latest MI (Management Information) in relation to TCF and of what steps you are taking to change behaviour if the data/reports suggest a risk to the fair treatment of customers.
- A TCF handout/leaflet summarising key points from the above.
Examples you might give of how TCF will affect your daily business could include:
- Written communication – using plain English, avoiding jargon or explaining jargon terms where they are unavoidable
- Promotions – ensuring that advertising/direct mail material is appropriately targeted, clear, not misleading and highlights the risks/conditions as well as the key features/benefits of a product
- Point of sale – putting in checks to ensure customers receive the right information at the right time and that their personal profile/attitude to risk is taken into account before a product is suggested or recommended
- Record keeping - keeping records on the client file demonstrating the reasons why a particular product was recommended if advice was given
- Sales – monitoring and rewarding not just volume, but also quality of information or advice provided (which in turn is evidenced in record keeping which feeds through to Management Information)
- After sales – encouraging contact with customers after a sale has completed, not only to research customer satisfaction but also, for example, to correct actions subsequently discovered not to be in line with TCF (eg mis-selling) or to highlight suitable products when a current deal is ending or no longer competitive
- Complaints – aiming to resolve complaints as soon as they come in; where this isn’t possible ensuring they are dealt with by an impartial, competent person and within FCA required deadlines
- Service improvements and corrective action – introducing incentives to encourage staff throughout the company to recommend changes they believe will offer customers a better service and/or a fairer deal
- Data protection – ensuring that staff are aware of and follow rules in relation to data protection, to ensure that clients’ details are kept secure and confidential
- Training and competency – ensuring all staff complete relevant training/exams to the level required by their areas of activity and within the timescales required by the FCA and keep up to date on product/industry developments
- Management Information – introducing TCF MI into regular MI reports (nature and volume of complaints, file check fails, etc) and using the information to identify problems and take corrective action where required
2. Create individual TCF learning plans for each staff member
In consultation with each staff member, consider drawing up an individual TCF learning plan to include training you or they feel would help them implement or develop ideas for TCF in their day to day activities.
In so doing, set objectives for staff to suggest ways to supportTCF within your business - to be reviewed at regular dates against performance.
3. Enrol staff for external TCF/other training courses
Find out what courses are available that complement TCF, including Training and Competency courses and workshops, and more general business skills courses.
4. Develop area-specific TCF in-house training
For ideas on what to include in in-house TCF training targeted at specific business areas follow the links below. These pages contain TCF Info material that you can download, adapt and own-brand to help you with training:
5. Keep a staff TCF training log
As part of TCF the FSA expect you to be able to show how you’re implementing the principle. A staff training log will provide the records you need to do this. It could also be combined with your general Training and Competence records, or kept separate. You could also keep a simple log evidencing product training and feedback to lenders.
6. Measure learning outcomes
You’ll need to measure the effectiveness of your TCF training.
You could do this either as part of an appraisal system, or through (for example) a quarterly ‘training review’ when you could:
- look at the training covered in the last period
- review individual (and/team) performance against TCF objectives set in the person’s area of activity
- offer rewards/incentives for exceptional performance or new ideas that have improved TCF in this area
- set new objectives if appropriate
If you keep a record of the training review, this will provide further evidence to the FSA that you’re implementing TCF training and awareness throughout your firm.