TCF customer statement

Consider providing your customers with a simple leaflet or statement advertising the fact that you support the TCF initiative. By showing your commitment to TCF in this way you’ll not only impress your customers, you’ll also demonstrate to the FSA that you’re embedding TCF into the firm’s culture. Example TCF customer statement

Talk customers through product features

If you don’t do so already, consider talking customers through product features rather than relying on them to read the literature alone. This way you can be sure they understand what they are buying.

Use disclosure documents as sales aides

Having announced TCF to your customer, consider using disclosure documents as positive sales aides rather than ‘required documentation’:

• by talking your customer through the items on the IDD you’ll not only ensure that they understand the type of service they’re being offered, you’ll also encourage them to value the integrity of the service you’re offering - this could influence whether they finally use your service or decide to go elsewhere
• by talking through the KFI you can be sure that your customer fully understands the features and costs of the mortgage – and in so doing add value to your service

Gather TCF feedback at point of sale

Encourage sales staff to gather TCF intelligence during the advice and sales process and give them a means to pass this information on– eg if customers commonly complain about not understanding a document/product, recording this information will enable action to be taken to correct the problem.  For more information on reporting and acting on TCF issues, see MI Tips and Tools.

Quality of advice - monitoring and incentives

Consider establishing quality standards linked to incentives for the sales process, such as completion of all sections the Fact Find and Product Suitability documents, and timely provision of disclosure documents – and records to back this up. Carry out regular monitoring (accompanied visits, mystery shopping, customer surveys, file checks and review of sales MI), and reward successful implementation.

To check whether your information gathering documents reflect key TCF points, see Fact Find checklist and Product suitability checklist.  For an example of how to record disclosure see the Client contact log. Also read our related Remuneration/incentives case example.

Non-advised sales

Require sales consultants to keep to the sales script - if they stray from it they could end up inadvertently giving advice.

The above said, if your firm provides a non-advised service, but during the course of a sale you suspect that a customer may be considering a mortgage that’s unsuitable for them, always tell the customer to seek advice. Whilst you can’t give advice, not to say anything would amount to ignoring the customer’s interests and therefore treating them unfairly.

Consider recording telephone sales in order to monitor your sales team. Thereafter you can discuss good and poor practices in on to one meetings

Training & competence

To comply with the MCOB and also satisfy TCF, you need to ensure that you have a system whereby:

• staff undergo the correct training for the level of advice they give, and complete it within the required two-year time limit
• partially qualified staff don’t issue advice, even under supervision
• there is a clear understanding of what competency means and you keep records to show how competency is maintained
• you have appropriate supervision for advisers who aren’t deemed to be competent (and therefore can’t issue advice)