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Treating Customers Fairly
(TCF):
What CEOs must know….

..to meet the challenge & reap the
reward.
                                     Stephen Rosling
                                             Director
Quick show of hands…
Thinking about your own organisation:

• How many have a TCF policy in place?

• How many have a role or function that is
  specifically responsible for TCF?
This session will…
•Give you a clear understanding of TCF and why it
 matters.

•Show you can use TCF to your advantage in

 ▫ Building better quality business
 ▫ Staying ahead of further consumer regulation.
The State of Trust
The State of Trust
Why does “trust” matter so much to
financial services customers?
  ▫ Intangible

  ▫ Long term

  ▫ Don‟t know if it‟s going to work until the point
    customers desperately need it

  ▫ Complex products; forced purchase
Why Should Anyone Buy From
You?
Costs of Getting it Wrong..

In the US: US$25 billion on residential mortgage lending
In the US: US$445 million on unfair, deceptive, abusive acts and practices
In the UK: US$ 15 billion on miss-selling of payment protection insurance
In HK:      US$ 258 million to compensate Lehman Brothers investors
(Data Source: KPMG Report Nov 2012)
The benefits of getting it right..

• Customers - US$ 23.2 billion

• Insurance industry - US$ 6 billion

• Government - US$7.4 billion

• Better customer engagement - US$1 billion
..more benefits of getting it right.
• Reputation
• Public trust
• Demonstration of commitment to social and
  governance issues (Corporate Social Responsibility)
• Improved customer advocacy

  “There can no longer be any doubt about the link
between protecting consumers from abusive products
 and practices, and the safety and soundness of the
                  financial system”
      Chair of the US Federal Deposit Insurance Corporation
The principles of TCF -
international
The OECD and Financial Stability Board‟s
universal “High Level Principles on Financial
Consumer Protection” relating to TCF:

• Equitable and Fair Treatment of Consumers
• Disclosure and Transparency
• Responsible Business Conduct of Financial
  Services Providers and Authorised Agents
• Complaints Handling and Redress
UK first on TCF principles
• Products and services marketed and sold in the retail market are designed to meet
  the needs of identified consumer groups and are targeted accordingly .

• Customers are provided with clear information and are kept appropriately informed
  before, during and after the point of sale.

• Where customers receive advice, the advice is suitable and takes account of their
  circumstances.

• Customers are provided with products that perform as firms have led them to
  expect, and the associated service is both of an acceptable standard and as they
  have been led to expect.

• Customers do not face unreasonable post-sale barriers imposed by firms to change
  product, switch provider, submit a claim or make a complaint.

• Customers can be confident that they are dealing with firms where the fair treatment
  of customers is central to the corporate culture .
Consumer Regulations…
                                              Authorisation
                                           Scheme for financial
                                                Advisers




                                     Treating Customers
                                        Fairly (2008)
                                     Retail Distribution
                                           Review
Dodd–Frank Wall
Street Reform and
    Consumer
  Protection Act

                    Treating Customers
                           Fairly
Consumer Regulations…                                Future of Financial
                                                           Advice
                           Framework for
                             Insurance
                            Advertising
  OCI proposal for new
 Independent Insurance
       Authority




Financial Advisory
 Industry Review




   Guidelines for
  Introduction of                             Financial
   New Products          Investment Adviser   Advisers
                            Regulations
                                                 Act
Building a culture of fair dealing:
the six crucial points of influence
• Leadership – TCF „championed‟ by CEO
• Strategy – vision/values; customer view;
  org.dev
• Decision-making –
  informed, empowered, open to challenge
• Controls – define, implement, report, review
• Recruitment, Training and Competence
• Reward – reshape around quality treatment of
  customers
TCF requires holistic effort along your
entire product value chain
•   Product Design
•   Product Development
•   Marketing
•   Sales
•   Customer Service/Maintenance
•   Claims/Maturity

• AND in all your support functions: IT, Finance
  and Accounts, Change Management, Facilities.
Step 1: Regulatory & Cultural
Audit
                                             Interviews
                                            Listening in

                                         TCF Training
          TCF Employee Communication and Engagement
                       TCF Policy/Customer Committee
                            TCF Escalation Processes
                         TCF Management Information

              Product development and review processes
                                    Marketing Materials
                    Sales processes and documentation
                                       Customer letters
                          Complaint Handling Processes
Step 2


• Analyse audit results

• Develop TCF action
  programme
Best practice example 1: TCF
Training
•   Mandatory attendance
•   Delivery
•   Annual refresher
•   Exam
•   Locations
•   Language
•   Board members
Training Messages..
Best practice example 2:
Customer Letters
• Tone – what will you say and how will you say
  it?

• Language – choosing the words

• Writing style

• Layout and presentation

• Grammar and punctuation
Best practice example 3 - TCF MI
•   12-month rolling report
•   Board Summary
•   Qualitative and quantitative data
•   Internal and external data
•   Align to principles of fair treatment
•   New and existing measures
•   Highly visual
•   Commentary provided by Senior Management
•   Action oriented
TCF MI examples…
Treating Customers Fairly is NOT..

•   About improving customer satisfaction
•   About treating all customers in the same way
•   Just about the quality of advice
•   A traditional “do once & move on” project
•   Only about compliance and risk management
Treating Customers Fairly IS....

• About building/restoring customer trust in
  financial services companies
• About cultural change
• About everyone playing their part
• A benefit, not just a cost
• About being able to prove that you treat your
  customers fairly.
“Brands must move from having nothing to
hide, to pro-actively showing and proving they
have nothing to hide” (Trendwatching.com)

“Trust grows at the speed of a coconut
tree, and falls at the speed of a coconut.”
Thank you
Contact Details               Contact Details
Email: stephen.rosling@tcf-   Email: john.ororke@tcf-matters.com
matters.com                   Tel: + 61 421 044 355
Tel: +44 7891 438 795

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Treating customers fairly what ce os must know- final

  • 1. Treating Customers Fairly (TCF): What CEOs must know…. ..to meet the challenge & reap the reward. Stephen Rosling Director
  • 2. Quick show of hands… Thinking about your own organisation: • How many have a TCF policy in place? • How many have a role or function that is specifically responsible for TCF?
  • 3. This session will… •Give you a clear understanding of TCF and why it matters. •Show you can use TCF to your advantage in ▫ Building better quality business ▫ Staying ahead of further consumer regulation.
  • 4. The State of Trust
  • 5. The State of Trust
  • 6. Why does “trust” matter so much to financial services customers? ▫ Intangible ▫ Long term ▫ Don‟t know if it‟s going to work until the point customers desperately need it ▫ Complex products; forced purchase
  • 7. Why Should Anyone Buy From You?
  • 8. Costs of Getting it Wrong.. In the US: US$25 billion on residential mortgage lending In the US: US$445 million on unfair, deceptive, abusive acts and practices In the UK: US$ 15 billion on miss-selling of payment protection insurance In HK: US$ 258 million to compensate Lehman Brothers investors (Data Source: KPMG Report Nov 2012)
  • 9. The benefits of getting it right.. • Customers - US$ 23.2 billion • Insurance industry - US$ 6 billion • Government - US$7.4 billion • Better customer engagement - US$1 billion
  • 10. ..more benefits of getting it right. • Reputation • Public trust • Demonstration of commitment to social and governance issues (Corporate Social Responsibility) • Improved customer advocacy “There can no longer be any doubt about the link between protecting consumers from abusive products and practices, and the safety and soundness of the financial system” Chair of the US Federal Deposit Insurance Corporation
  • 11. The principles of TCF - international The OECD and Financial Stability Board‟s universal “High Level Principles on Financial Consumer Protection” relating to TCF: • Equitable and Fair Treatment of Consumers • Disclosure and Transparency • Responsible Business Conduct of Financial Services Providers and Authorised Agents • Complaints Handling and Redress
  • 12. UK first on TCF principles • Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly . • Customers are provided with clear information and are kept appropriately informed before, during and after the point of sale. • Where customers receive advice, the advice is suitable and takes account of their circumstances. • Customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect. • Customers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint. • Customers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture .
  • 13. Consumer Regulations… Authorisation Scheme for financial Advisers Treating Customers Fairly (2008) Retail Distribution Review Dodd–Frank Wall Street Reform and Consumer Protection Act Treating Customers Fairly
  • 14. Consumer Regulations… Future of Financial Advice Framework for Insurance Advertising OCI proposal for new Independent Insurance Authority Financial Advisory Industry Review Guidelines for Introduction of Financial New Products Investment Adviser Advisers Regulations Act
  • 15. Building a culture of fair dealing: the six crucial points of influence • Leadership – TCF „championed‟ by CEO • Strategy – vision/values; customer view; org.dev • Decision-making – informed, empowered, open to challenge • Controls – define, implement, report, review • Recruitment, Training and Competence • Reward – reshape around quality treatment of customers
  • 16. TCF requires holistic effort along your entire product value chain • Product Design • Product Development • Marketing • Sales • Customer Service/Maintenance • Claims/Maturity • AND in all your support functions: IT, Finance and Accounts, Change Management, Facilities.
  • 17. Step 1: Regulatory & Cultural Audit Interviews Listening in TCF Training TCF Employee Communication and Engagement TCF Policy/Customer Committee TCF Escalation Processes TCF Management Information Product development and review processes Marketing Materials Sales processes and documentation Customer letters Complaint Handling Processes
  • 18. Step 2 • Analyse audit results • Develop TCF action programme
  • 19. Best practice example 1: TCF Training • Mandatory attendance • Delivery • Annual refresher • Exam • Locations • Language • Board members
  • 21. Best practice example 2: Customer Letters • Tone – what will you say and how will you say it? • Language – choosing the words • Writing style • Layout and presentation • Grammar and punctuation
  • 22. Best practice example 3 - TCF MI • 12-month rolling report • Board Summary • Qualitative and quantitative data • Internal and external data • Align to principles of fair treatment • New and existing measures • Highly visual • Commentary provided by Senior Management • Action oriented
  • 24. Treating Customers Fairly is NOT.. • About improving customer satisfaction • About treating all customers in the same way • Just about the quality of advice • A traditional “do once & move on” project • Only about compliance and risk management
  • 25. Treating Customers Fairly IS.... • About building/restoring customer trust in financial services companies • About cultural change • About everyone playing their part • A benefit, not just a cost • About being able to prove that you treat your customers fairly.
  • 26. “Brands must move from having nothing to hide, to pro-actively showing and proving they have nothing to hide” (Trendwatching.com) “Trust grows at the speed of a coconut tree, and falls at the speed of a coconut.”
  • 27. Thank you Contact Details Contact Details Email: stephen.rosling@tcf- Email: john.ororke@tcf-matters.com matters.com Tel: + 61 421 044 355 Tel: +44 7891 438 795