Seeking fair counsel

The FSA has given firms until the end of March 2008 to set up TCF measurement systems so that by December 2008 you will be able to prove you are treating your customers fairly in the majority of cases.

Part of its focus will be on the management culture within firms, so your staff should continue to make sure that TCF is embedded into everything the firm does.

The help means the watchdog will be increasing its contact with small firms to accelerate progress towards meeting the deadlines. This could be a telephone discussion of the steps taken by the firm, or a visit, or both, and the FSA says it expects to visit around a quarter of firms.

These visits will enable the FSA to provide guidance or supervision to firms, but you should not wait to begin the process of change; the risk-based nature of the regulation means that firms will need to decide what is appropriate to their own businesses.

As with any measurement of performance, the key will be relevant and timely management information that proves that the desired outcomes are being met. You could refer to the TCF Culture and TCF Management Information publications, which give examples of good and poor practice, however those firms that benefit from the assistance of a compliance consultant will undoubtedly receive guidance on the range of sources that will apply in their specific case.

- Ian Ritchie, Managing director, RW Associates.