TCF Info: Supporting mortgage brokers and intermediaries in the FSA principle of 'treating customers fairly' (TCF).
Search this site
Home
TCF Info at a glance
What is TCF?
TCF Deadlines and Monitoring
TCF Principles Checklist
Tips and Tools
Case Studies
Resource List
News, Hot Topics and Events
Register Here

Free registration for our regular Newsletter and new content updates

Send to colleague

Send a link to this page to a colleague.

MPPI and TCF

  MPPI - non-advised sales tips

To demonstrate TCF for a non-advised sale, you’ll need to evidence to the FSA that you have controls in place to prevent sales staff:

  • inadvertently offering advice to the customer
  • providing information on policies selectively

These controls might include:

  • procedures requiring the consultant to confirm in writing and to the customer how many products are available that meet their demands and needs in full or in part – giving the customer all of the possible options
  • sales scripts designed and tested to ensure the benefits of a given product are balanced against the limitations
  • sales scripts designed to ensure that one product isn’t inadvertently ‘promoted’ over and above another
  • regular training/refresher courses in how to conduct a non-advised sale – with related exams/tests
  • ‘lessons learned’ workshops when mistakes are made
  • regular monitoring of sales consultants via file checks and telephone monitoring
  • partially withheld bonuses for failure to follow telesales scripts or procedures for non-advised sales
  • a balanced approach to incentives – for example rewarding in equal measure a compliant non-advised sales procedure which does not proceed to a sale and an actual sale
  • using your own and insurers’ MI (Management Information - eg cancellation statistics by product or staff member) to target compliance monitoring in the highest risk areas
  • records to evidence all of the above

Bear in mind that the FSA states that if you aren’t able to put in place adequate controls to prevent advice being given, you would need to sell on an advised basis and comply with suitability rules. This may mean applying for a variation of permission. For FSA guidance on what constitutes advice read the perimeter guidance (PERG 5.8) on the FSA website.

FSA related links

FSA perimeter guidance on what constitutes advice (opens new window)
This site is owned and managed by Frank Eve Consulting Limited.
© 2006 TCF INFO
This site provides information for UK regulated mortgage intermediaries only and whilst TCF Info has made every reasonable effort to check the accuracy of the material, TCF Info cannot be held responsible for any inaccuracy or omission. All users should read the Terms and Conditions.