TCF – Are we ready?

The next TCF deadline is looming!  From the 31^st of March all firms must have the systems in place to provide sufficient management information to check and prove that they are meeting the TCF standards.  Regardless of the March deadline, having the correct management information (MI) in place will be an essential part of moving toward the following deadline in December 2008 when firms must be able to demonstrate that they are using a wide range of quantitative and qualitative measures that they are consistently treating their customers fairly.  Having access to relevant MI will not just enable the firms to measure and guide their TCF processes, but it will also help drive cultural change.  Visibility and transparency generally reduces bad practices more quickly than other methods.  However, is the industry truly embracing the TCF changes?  On the whole yes.  But, and it is a big BUT, not everyone is on board and those that are, are often not quick enough.  Back in November the FSA were highlighting the fact that the speed of movement to TCF compliance was too slow, particularly in meeting the core principals of providing accurate, informed advice supported by sufficient customer information.  This somewhat lethargic approach has been re-confirmed in a recent survey by Mortgage Solutions which showed that with 2 months to go 24% of the 960 brokers sampled had only a vague idea of the TCF requirements with a further 3% having no idea at all! The same survey showed brokers appreciate the necessity of regulation with 44% saying it has had a positive impact on consumer perception of the industry against a mere 14% saying that it has had a negative impact.  So why is the industry slow or reticent in responding?  The technical solutions are there to help, the reward of better consumer perception and the resulting increase in trust is also there.  Alongside the positives, there is the ever present threat of punishment for non compliance too (and never been more real)… So let’s get on and do it!