Early on, the FSA identified ‘four phases of progress’ towards TCF. The deadline for the first two (‘awareness’ and ‘strategy and planning’) has now passed. In addition, firms were expected to have reached the ‘implementation’ stage of TCF MI (management information) by the end of March 2008. However, if you’re just setting up in businesses all of the TCF planning phases will be relevant for you. They are:
- Awareness (analysing what TCF means, attending workshops, and/or using consultants)
- Strategy and planning (determining what approach or processes your firm needs to adopt in order to implement TCF; involving the key players; communicating the approach or processes to staff)
- Implementation (allocating resources and responsibilities, developing plans and creating capabilities)
- Embedding – following up on implementation; continuous monitoring of TCF performance and commitment to maintaining standards in the future
For more detail on TCF deadlines read the section TCF Deadlines and Progress Monitoring.
Planning in practice
Bear in mind that the FSA:
- accepts that many smaller firms don’t tend to approach TCF by looking at processes, carrying out gap analyses and developing a formal strategy – however you do need to be able to show how you have developed your plan
- doesn’t expect each area of a business to be at the same stage of progress – some areas of your business may reach the ‘implementation’ and ‘embedding’ milestone before others (especially if you’re a larger firm and decide to approach the task in a ‘risk based’ way)
- is more interested in the quality of what your firm is doing and how this is changing behaviour to achieve fair treatment and the six customer outcomes, than simply the speed with which you’ve progressed through an action plan (however the March 2007 deadline still applies for the majority of your business)
- considers that senior management won’t be able to assess their TCF performance adequately or to conclude they are ‘embedding’ until they can judge the firm’s performance against appropriate management information - as described above, the deadline for implementing TCF MI was March 2008 so most firms should be doing this by now
TCF planning - where to start (new firms)
If you're a new firm a good starting point for implementing a TCF strategy in your business is for the business owner (in a small firm) or Senior Management (in a larger firm) to write a TCF 'objectives statement' with which all staff become familiar, either at the creation stage and/or through TCF training.
Your objective statement will ideally:
- define what TCF means for your firm
- set out high level TCF principles/objectives relevant to your particular business activities
Try to make it implicit in your objective statement that TCF:
- will become integral to the way your firm carries out its day to day business
- applies to all areas of your business, from the top down
- is endorsed by Directors and Senior Management (where relevant)
- will add value to (not compete with) your existing business strategies
- benefits both your customers and your business
- is an ongoing journey rather than a destination
Using your TCF objectives statement
Having defined your high level objectives and principles you can:
- develop an action plan to ensure the TCF principles are reflected in the practices you develop in the different parts of your business
- once the new initiatives are in place, regularly measure their effect using management information
For an example objectives statement that you can download and adapt for your business, follow the link below.
For more ideas on creating TCF awareness, visit the TCF Training section.
For ideas on how to carry out a gap analysis and start implementing TCF in different areas of your business, visit our Principles Checklist and MI Tips and tools sections