Julia Williams identifies the six areas to maintain a culture which benefits all.

In 2006 the Financial Services Authority (FSA) set out its intentions to promote a new framework which it named Treating Customers Fairly (TCF), underpinning the delivery of statutory consumer protection. The aim was to move to a more principle-based approach to regulation.

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Six years on, TCF has changed the culture and the way business is conducted, one which must continue to be embraced by us all, from motor dealers to lawyers alike. TCF pervades business consumer life, from the presentation of products and services, to sales, collection and recoveries
activities – it remains at the core of the whole customer experience.

So how do we maintain this culture? The answer lies in six very definitive areas: leadership, strategy, decision making, controls, performance management, and reward. It is crucial that, from the top downwards, management instills a culture among staff to understand what fair treatment of customers actually means, and to put this into operation from the outset, moving away from a
more traditional reactive approach.

Businesses should seek to establish TCF objectives and allow polices and procedures to be driven by such objectives, allowing the culture to evolve. Commitment to TCF should be demonstrated by clear messages, training for staff and monitoring of performance to flag
weaknesses in knowledge and to identify poor performance.

Strategy and decision making come very much hand in hand. Understanding consumer needs and evaluating feedback is an excellent way to devise business strategy and to develop products and services consistent with TCF requirements.

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The delivery of fairness is further achieved by the recruitment of staff with the appropriate knowledge, values and skills to absorb and promote the business’s vision to achieve requisite TCF standards.

Robust monitoring of customer outcomes should be closely linked to staff incentive and reward / recognition schemes focusing on service delivery and excellence. Since 14 January 2005, the FSA has regulated the motor industry in relation to the sale of insurance-related products connected to a vehicle purchase. In addition, the Finance and Leasing Association (FLA) views TCF as central to its beliefs, which means that every motor dealer and lender should encompass TCF as a trading style if they are not to fall foul of the initiative. Compliance ensures customer confidence and demonstrates the operation of a responsible business.

The FLA coined the phrase ‘Good for the consumer, good for the industry and good
business sense’. These are wise words in challenging times.

Julia Williams is a partner and head of debt and asset recovery at Chafes Solicitors