Speaking at the Personal Finance Society’s TCF conference in London last week, BDO Stoy Hayward director John Porteous said there is no single measure of TCF as it is linked around products, technology, process and not treating customers identically.
He said: “It is important to treat clients as individuals but you also need to deliver a consistent investment process and consistent output.”
Castle Court Consulting director Richard Gough said firms must look objectively at the measures they have put in place and be willing to update them regularly.
Gough said: “Firms must understand and accept their processes may not be right at the outset and have the courage and conviction to change. Firms must question, challenge and review their process regularly.”
Rennison Consulting director Roderic Rennison said giving evidence of TCF is the key to meeting the FSA’s December deadline. He said firms may have procedures in place but they must also be able to demonstrate that they meet TCF in practice as well as in theory.
Rennison added that firms must make a member of management accountable for implementing TCF. He said: “The reason why TCF has not made as much progress as it could have is because people are told to do something but there are no consequences for not doing it.”
FSA small firms division investments manager Mark Wilson said there will ultimately be differences in the way advisers implement TCF but the important thing is that everyone reaches the same end point of treating their customers fairly.
Wilson said: “It is incredibly important that consumers have confidence in the advisory sector. TCF is part of building market confidence.”