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Management Information (MI)

TCF - MI checklist

Our TCF MI (management information) checklist below will help you identify data that could be used to measure and improve TCF performance in your business against the six TCF consumer outcomes. While all six outcomes are relevant across all areas of business activity we’ve indicated below those we think are the most relevant for given MI data – and against which the FCA is therefore likely to be measuring the quality of your MI.

  • As described in our pages TCF – getting started and TCF MI – key principles for each set of data you choose to measure you’ll need to set targets which will help alert you to whether or not there is a TCF risk.
  • Where a risk is identified, you’ll also need to evidence what action you took to investigate the cause and what corrective action you took or are taking as a result. Each section of the checklist below is followed by a download version with extra columns to help you do this.
  • Green, amber and red indicators in MI reports can provide an ‘at a glance’ view of TCF performance and risks – with amber being used to highlight a potential problem early on, enabling early action to solve it. 

Bear in mind that gathering ‘qualitative’ MI data (feedback in the form of opinions) is just as important as collecting quantitative data (based on volumes/numbers). Both types of MI are covered in the tables below.

 For a reminder of the six consumer outcomes read the page What is TCF?

Sales (Outcomes 2, 3, 4 and 5)

Data measured (MI)

What this MI shows

Sales volume by product type (add risk rating for each product?)

Product suitability – excessive sales of one product may indicate mis-selling/unsuitable sales including inadequate assessment of affordability.

Sales volume by commission rate/type (mortgage and insurance products)

Commission rate payable on a particular product may result in product bias, leading to mis-selling/unsuitable sales. As above, may mean affordability wasn’t properly assessed.

Sale volumes of extended tie-in

Excessive sales may indicate customers aren’t being sold the most suitable product - may include inadequate assessment of affordability.

Sale volumes of Self Cert (measured against expected targets)

Higher than expected volumes of Self Certification sales could indicate mis-selling, resulting in some customers (who can prove their income) paying an excessively high interest rate. May have implications for affordability.

Sales volumes of PPI

Excessive penetration rates may indicate mis-selling/unsuitable sales.

Sales volume against expectations

Poor sales may indicate wrong targeting or product too complex; excess sales may indicate mis-selling/unsuitable sales, including affordability concerns.

Offer to completion rate

A high drop off rate between offer and completion may indicate unsuitable sales.

Offer to completion time

Very short completion times may indicate the customer has had inadequate time to consider the terms of the offer and/or has been pressured into accepting a product they do not fully understand.

Cancellation within cooling off period (insurance products)

High cancellation rates may indicate unsuitable advice and/or a misunderstanding of the product on the part of the customer.

Early redemption rates on limited period products

Excessive early redemption rates may indicate a lack of suitability of advice as customer believes product is unsuitable or can’t afford it and terminates early

Percentage of file check fails – total and by adviser (based on a sample of files)

By firm/adviser - evidence of systemic weaknesses and/or breaches of the Conduct of Business regulatory requirements (including disclosure) which may result in misleading or insufficient information being given and/or mis-selling. By adviser – may evidence T&C shortcomings and training needs.

Number of new products introduced during a given period

Review in conjunction with product training statistics (see below).

Percentage of sales staff completing new product training within a given period

Training and competency of advisers is a key component in ensuring that customers are treated fairly. Poor product knowledge may lead to an inappropriate recommendation.

Corrective/preventative action that could be taken where MI indicates a risk of unsuitable sales

Check Fact Find for completeness. Do the questions allow the broker properly to assess suitability and affordability? See our Fact Find checklist and Product suitability checklist

Carry out file checks – is the Fact Find being fully completed? If not consider imposing penalties or commission withdrawal and disallow independent sales until re-training is complete. For ideas on how to use the MI to change sales behaviour read our Remuneration/incentives case example and Product suitability case example.

Complaints (Outcomes 1-6)

Data measured (MI)

What this MI shows

Volume of complaints

May indicate mis-selling or other failings affecting the fair treatment of customers.

Complaints against adviser/AR

As above, may reveal a training need.

Complaints by branded product

May indicate product and/or provider’s marketing material is unclear or misleading or unsuitable for the target market. This could lead to mis-selling or other unfair treatment of customers.

Complaints relating to broker information supplied

Could indicate either or both of:

  • a lack of clarity and completeness of Key Facts and other documents/correspondence supplied by the broker, or in the advice given
  • deficiencies in the product information provided by the provider to the broker

Complaints upheld internally – broken down by key category (see FSA list)

May reveal trends depending on the underlying reasons and the need for improvements in the relevant areas. May be a measure of the fairness of the complaints handling procedures.

Complaints not upheld internally – as above

May identify possible areas of misunderstanding (assess possible action to reduce this). May indicate unfairness in the complaints handling process.

Volume and percentage of complaints referred to FOS

External measure of complaints handling process.

Percentage of complaints to FOS upheld

May indicate unfairness in the firm’s complaints handling process.

Percentage of complaints to FOS not upheld

May be indicative that a firm’s complaints handling process is fair and resulting in the right outcomes.

Percentage of complaints acknowledged within 5 day deadline

Performance measurement of timeliness of complaints handling process.

Percentage of complaints resolved within 5 days

Performance measurement/complaints being handled in a fair and timely manner.

Percentage of complaints resolved within 4 weeks

Performance measurement/complaints being handled in a fair and timely manner.

Percentage of complaints resolved within 8 weeks

Performance measurement/complaints being handled in a fair and timely manner.

Number of RFCs raised (‘Recommendation following complaint’)

Action being taken to improve standards. (For more information on RFCs see the section Complaints tips and tools) Could be evidence of a TCF culture and embedding.

Number of RFCs resulting in a change to procedure or policy

Action taken to improve standards/reduce complaints. Could be evidence of a TCF culture and embedding.

Point of sale and pre-completion (Outcomes 2, 3, 4)

Data measured (MI)

What this MI shows

Score rating of quality of advice/information provided following mystery shopping/telephone or other monitoring

Measure of the quality of advice and information provided - and by sales consultant/adviser. Shortcomings may result in unsuitable sales or other unfair outcomes.

Volume of pre-completion customer queries by product

May indicate quality of advice and/or clarity of product information, or that product is overly complex for target customers.

After sales service
(Outcomes 1,2,3,4 and 6)

Data measured (MI)

What this MI shows

Percentage of clients contacted within X months/years of completion and reason for contact

May be a measure of the standard of customer care, depending on the reason for the contact.

Clients on non-tie in variable rates contacted after base rate rise to alert them to a better deal

May be a measure of the standards of post sale customer care.

Clients contacted within 3 months of tie-in end to alert to deals other than variable rate

May be a measure of the standards of post sale customer care.

Clients contacted to notify unsuitability of product following TCF review

Indicative of the existence of serious compliance breaches at the point of sale and possibly in other areas resulting, in mis-selling. May be indicative of wider systemic shortcomings.

Percentage of clients contacted following completion with satisfaction survey

Fairness related questions (eg ‘what does this product do’/’why did you buy it’) and questions relating to whether the customer understood what type of service they received may indicate whether customer has been treated fairly.

Overall service satisfaction score for this period out of 10

May indicate whether customers are being fairly treated, depending on the questions asked.

Culture and values (Outcome 1)

Data measured (MI)

What this MI shows

Percentage of staff who’ve completed general TCF training – sales and non-sales

May be indicative of TCF awareness and a TCF culture and communication strategy.

Percentage of staff who’ve completed additional TCF training specific to their area

As above – likely to further enhance TCF awareness and the development of a TCF culture and embededness.

Number of consultants who received retraining following high volumes of complaints/file fail checks

May be indicative of TCF awareness and a TCF culture – firm is routinely identifying and acting on TCF issues.

Number of TCF goals in place by business area (advice, complaints, advertising, after-sales service)

May be indicative of TCF awareness and an embedded TCF culture.

Percentage of TCF goals achieved by business area for this period

As above

Number of sales/non-sales staff rewarded for meeting TCF targets?

As above

Number of staff rewarded for suggestions to improve service (whether following complaints or otherwise)

As above

Culture and values – qualitative MI

Nature of Qualitative MI

What this MI shows

Documented TCF strategy/plan

Senior management/business owner commitment and strategy.

TCF MI reports, regular minutes of meeting, reporting structures and review processes.

Embedding of TCF culture and use of TCF MI is being identified, reviewed and acted on.

Minutes evidencing monthly review of TCF MI by senior management or business owner and/or TCF Committee or Champion and actions taken in response

As above

Staff surveys/opinions on how TCF is working and on how it could be improved

Captures staff perception of how fairly a firm treats its customers. Further evidence of embedding of TCF culture.

Advertising and Financial Promotion (Outcomes 2, 3 and 5)

Data measured (MI)

What this MI shows

Volume of complaints by promotion type (advertisement, DM)

Could indicate that promotion is unclear or inaccurate, depending on the nature of the complaint.

The nature of the complaint, root cause, and decision taken can indicate whether a customer has been treated fairly.

Number of compliance breaches picked up by the in-house approval process

May indicate:

  • approval processes are operating satisfactorily
  • a poor technical understanding in the marketing areas – training need
  • a poor understanding of what constitutes using clear, fair and not misleading information – training need

Number of compliance breaches picked up by FCA

Misleading information reaching the customer. May indicate problems with the approval process and/or a poor technical understanding in the marketing areas.

Number of promotions pre-tested with target customers

Evidences embedding of TCF in financial promotions development.

Product feedback to providers (Outcomes 1 and 5)

Data measured (MI)

What this MI shows

Number of cases of product feedback/suggestions to providers to assist TCF

Feedback on the quality/suitability of a product and/or clarity of product information may improve consumer outcomes.

 

Strategy – qualitative MI
(Outcome 1)

Nature of Qualitative MI

What this MI shows

Documented process for assessing impact on customers before product change or strategic change

Any adverse impact that could result from a change will be identified and addressed.

The firm has a strategic commitment (documented) to avert major TCF risks/failings through ongoing scrutiny of sales targeting of products

Firm’s commitment to prevent major TCF failings – such as endowment mis-selling.

Qualitative feedback from customers
(Outcomes 3, 5 and 6)

The FCA has highlighted the usefulness of qualitative as well as quantitative feedback when assessing fairness – for example, customer understanding of the product or service they have received. If you wish to carry out post sales market research with your customers, this might involve asking open ended questions such as ‘What does this product do?’ or ‘Why did you buy it?’ Where relevant, product feedback could be passed back to the lender.

To test understanding of the service you might ask ‘Did you buy based on advice and a recommendation or information only?’, ‘How were you charged for this product?’ or ‘Was the product selected from the whole market or from a limited choice of providers?’ Go to our After sales customer survey page to find out more.


Qualitative feedback from staff
(Outcomes 1 - 6)

Consider holding periodic feedback sessions/workshops with staff to ask their opinions on whether they feel the products and service the company is selling pose any risk to the fair treatment of customers – and ideas for how to minimise this risk. In addition consider having a TCF staff suggestion scheme related to incentives.

Keep a record of all opinions and suggestions and hold periodic meetings to consider whether any can be taken forward. Keep a note of the outcomes of these meetings – including what action is taken (and if not, why not). Pass the notes from these meetings to senior management for consideration.

All of these records will evidence embedding of TCF culture in your business as well as helping you identify where action can be taken to implement TCF.

This is a general guide only - the extent of MI you’ll need will depend on the nature and size of your business.

FCA links

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