BPF - Treating customers fairly - Barclays · 2/13/2018 · Treating Customers Fairly is about every single interaction with your customer but it shouldn’t be hard to achieve if

TCF aims to:

• Help customers fully understand the features, benefits, risks and costs of the financial products they buy

• Give customers the information they need to make informed decisions about the products they choose

• Minimise the sale of unsuitable products by encouraging good and reasonable practice before, during and after a

sale

TCF is more about your company culture and doing business in a way that will help ensure customers get fair

treatment.

Here we look at how you can embed the six guiding principles of consumer outcomes in your financial promotions

and processes to help you to stay compliant.

Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is

central to the corporate culture

The FCA is looking for firms to develop cultures where good governance is inbuilt rather than being an ‘add on’

activity.

Treating Customers Fairly

Partner Finance

Treating customers fairly and delivering good

customer outcomes is more than just a

regulatory requirement; it goes hand-in-hand

with increasing consumer trust and brand

advocacy, as well as helping to reach your

commercial goals.

More than 10 years after it was first

announced, The Financial Conduct Authority

(FCA) continue to have ‘Treating Customers Fairly’ (TCF) at the heart of their approach.

Barclays Partner Finance is a trading name of Clydesdale Financial Services Limited, a wholly owned subsidiary of Barclays Bank PLC. Clydesdale Financial Services Limited is authorised and regulated by the Financial Conduct Authority (Financial Services Register number: 311753).Registered in England. Registered No: 2901725. Registered Office: 1 Churchill Place, London E14 5HP.Finance is subject to status and only available to UK residents aged 18 and over.

You could help achieve this outcome by considering:

• Compliance is at the centre of your processes and not a check box exercise overlaid at the end,

• Everyone is accountable for TCF principles as a collective business ethos,

• You encourage openness and honesty and make it easy for people to ‘own up’ to compliance slip-ups.

An element of automation in your processes may help to make the necessary reviews, approvals and audit trails

compulsory and ultimately save time overall.

Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of

identified consumer groups and are targeted accordingly

Making sure your financial promotions are relevant to your customer audience with messages that are clear, fair and

not misleading is one of the key objectives for the FCA.

This means:

• Not making claims about products that can’t be substantiated, or that your audience may not easily understand,

• Avoiding financial jargon or technical terms that may be confusing,

• Getting the disclaimers or disclosures right,

• Using copy that informs, not advises i.e. making your audience aware of features and benefits, not directing them

to do something,

• Marketing and compliance working together from the start of any project,

• Thoroughly assessing customer affordability (see our video guide to Assessing Customer Affordability).

Encouraging your marketing and compliance teams to work closely together from the start of a project could help

you to achieve this outcome, but may also help to get marketing materials produced faster and more efficiently –

saving both time and money.

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and

after the point of sale

This outcome applies to any time you interact with customers or prospects, not just in the run up to a sale, but

communications with existing customers too.

Partner Finance


You could help achieve this outcome by:

• Considering the whole customer journey and how you communicate at each stage,

• Keeping an audit trail to evidence the review and sign off process to show promotions have followed the

correct procedures,

• Demonstrating that review and sign off have been carried out by an appropriately qualified person,

• Making sure the customer is aware of the key points of the finance, before they sign up to a product,

• Keep a copy of all correspondence with customers.

Mapping out your customer journeys can help you to consider where there may be gaps in your communication or

where it could be improved. Not only can this help to achieve consistent customer outcomes, it could also help

acquire new customers and retain existing customers for longer.

Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances

The FCA is increasingly focussed on a company culture where the customer’s best interests are at the heart of the

process. Ultimately this leads to consistently good customer outcomes.

In relation to this outcome, you could think about:

• The best fitting solution for each customer - even if that customer comes with a strong opinion on what they

believe they need,

• Embedding a customer centric culture, not relying solely on checklists to be compliant,

• Including the relevant risk warnings or illustrations and making it clear to customers with illustrations,

• Making TCF principles part of your continual staff training.

Utilising new technology such as Sign Anywhere from Barclays Partner Finance can also help give digital assurance,

ensuring you have documented that customers understand the information they have provided, the advice given,

and the key features of the loan product that they are signing up for.

Partner Finance


Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the

associated service is of an acceptable standard and as they have been led to expect.

This outcome will (at least partly) rely on product performance provided by third parties so it’s important to ensure

that the solutions you choose to provide to your customers take into account TCF principles.

To set customer expectations of the products you provide, you could also think about:

• Where to include relevant risk warnings and disclaimers in any communications and sales discussions,

• Making sure these warnings/disclaimers meet the prominence requirements so that customers don’t miss them.

Being clear with customers from the outset to highlight what they can expect from the product will set customer

expectations for the future, helping to ensure customers have a good overall experience and increase customer

retention.

It’s also important to note here that your sales staff should have a good, solid understanding of the products they

are advising on so regular training updates that include both product information and TCF principles will be

beneficial.

Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch

provider, submit a claim or make a complaint

Compliance should be at the heart of your corporate culture and with robust processes in place then this outcome

should be straightforward to achieve.

Think about:

• Including post-sale communications in your customer journey mapping to see how straightforward it really is for

a customer to communicate with you,

• Analysing feedback received will help flag opportunities for you to improve processes,

• How you handle any customer complaints or supporting a customer post-sale.

Partner Finance


Treating Customers Fairly is about every single interaction with your customer but it shouldn’t be hard to achieve if

you have robust processes in place for compliance. Embedding these principles at the heart of your company culture

can ultimately drive up customer satisfaction, creating trust and longevity in customer relationships. Remembering

the golden rule to ‘treat your customers how you would want them to treat you’ will stand you in good stead.

Embedding TCF principles at the heart of your company culture can drive up customer satisfaction and create trust

and longevity in customer relationships.

Partner Finance


Disclaimer:

This document has been prepared by Barclays Partner Finance (Barclays) and is provided for information purposes

only. The accuracy or completeness of any information herein which is stated to have been obtained from or is

based upon any third party sources is not guaranteed by Barclays. Barclays accepts no liability for the impact of, or

any loss, however arising, from, any decisions made based on the information contained within this document.

References:

Financial Conduct Authority, Fair Treatment of Customers web page updated 13/02/2018:

https://www.fca.org.uk/firms/fair-treatment-customers

Financial Conduct Authority, Treating Customers Fairly – Culture:

https://www.fca.org.uk/publication/archive/fsa-tcf-culture.pdf

Financial Conduct Authority, Treating Customers Fairly – Guide to management information:

https://www.fca.org.uk/publication/archive/fca-tcf-mi-july2007.pdf

Financial Conduct Authority, Treating customers fairly – towards fair outcomes for consumers:

https://www.fca.org.uk/publication/archive/fsa-tcf-towards.pdf

Partner Finance


https://www.fca.org.uk/firms/fair-treatment-customers

https://www.fca.org.uk/publication/archive/fsa-tcf-culture.pdf

https://www.fca.org.uk/publication/archive/fca-tcf-mi-july2007.pdf

https://www.fca.org.uk/publication/archive/fsa-tcf-towards.pdf

Documents

BPF - Treating customers fairly - Barclays · 2/13/2018 · Treating Customers Fairly is about every single interaction with your customer but it shouldn’t be hard to achieve if