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Is the 31 March deadline for the implementation of MI, to prove your firm is achieving the TCF outcomes, 'Mission Impossible ‘08' or 'A Simple Plan'?
The good news is that you may already have done significant work which will assist you with this task. This should have identified what the TCF outcomes mean in practice for your firm and started to disseminate the culture of TCF throughout the firm, as well as having defined the boundaries of your TCF responsibilities. This is particularly important where the firm is just one link in the chain between product provider and ultimate distributor. You will probably also have a significant amount of MI at your disposal which can be used for this purpose.
Caution is required, however. MI which has been implemented to demonstrate service levels, performance or customer satisfaction may look useful but will have been designed with a different purpose in mind. As the FSA states, satisfied clients have not necessarily been treated fairly, and vice versa. The point here is to gear the measurement towards your application of the six TCF outcomes, showing achievements in relation to those specific requirements.
To achieve this, you may need to analyse your current information from a different perspective or increase its granularity to identify, for example, fairness of treatment between different classes of clients as well as consistency of delivery with reasonable expectations across the client base as a whole. The intelligent and knowledgeable analysis of what the data means in relation to TCF is a key component of the TCF process and will require support from experienced, competent staff as part of the governance process. MI gives indications of where to look, but not necessarily the answers.
Bearing in mind the need to measure achievements, it is equally important to demonstrate what has gone well, in addition to identifying any causes of dissatisfaction or failure to deliver what was promised. So, for example, positive customer feedback should be recorded alongside any feedback from consumer forums or mystery shoppers.
The key to successful achievement of the MI target is evidence. As is always the case, unless you can prove what you have done, it didn’t happen. If you have procedures that state how clients should be treated in particular scenarios, you need to be able to easily retrieve data to show that you have followed that procedure. This could be difficult, depending upon how your data is recorded and structured, so you will also need to consider the accessibility of this information.
Finally, though, there is more good news. The work that firms put into defining and implementing MI to meet the TCF requirements should be valuable to the firm in other ways. The measurement of whether the firm has achieved what it said it would do will help the firm commercially, as it will cover:
• The effectiveness and comprehensiveness of its communications to clients
• The effectiveness and quality of staff training and their adherence to and understanding of TCF procedures
• The ongoing fit between the products being sold and the clients’ needs and expectations
For more information on the MI requirements for TCF, what to prove, what to get and the evidence, analysis and action required, please contact Mark Lester or Karen Bond at Morse.
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