24
BUSINESS STRATEGIES EXPORTING TCF
tive, Tim Searle, says it
adopts a highly clientfocused
approach. He
explains: “TCF makes business
common sense. These
people are your buyers and
if you look after them they
will buy again. We place a
heavy emphasis on referral
marketing – new business
is time consuming and
expensive. If you are looking
after those people who
refer you on, it is a lovely
virtuous circle.”
Gill agrees. “We have
corporate values and a culture
that prevails and TCF is
a big part of that culture.”
Although to date it is
not something that firms
such as FPI have been
compelled to do, Gill says
it has been a case of picking
and choosing the parts
of TCF that work. “The key
is the five goals [see box,
page 23]. That gives you a
good feel for what they are
trying to achieve.”
l Following own rules
Dubai operates under a
much less stringent regulatory
regime than many jurisdictions;
hence the onus is
on adviser firms to be to
some extent self-regulating.
“To us it is second nature,”
says Searle. “This is what
we do. We do not need the
FSA to tell us what to do.”
Globaleye has addressed
TCF partly by investing
heavily in a customer
relationship management
(CRM) system. “We have
made a big commitment to
using IT,” says Searle. “We
spend a lot of money and
resources on our online
CRM system. It makes us
look good in the eyes of
the client by updating them
every month.
“We need to make
sure the data is updated
properly, but we can then
drill down into our data to
ensure our message to cli-
ents is more relevant. It is
a reverse sell. Some clients
do not want to speak to
their broker because they
say: ‘Every time I speak
to you I end up signing
bits of paper.’ It is a softer
approach. They can speak
to our CRM department.
We do not want clients
going to life offices – we
want them coming to us.”
call the MD letter to clients
twice a year, saying thanks
for being part of our success
and including a questionnaire
to ensure we have
up-to-date information. Life
offices do not interact with
their clients, but we are the
ones at the coalface.”
The Fry Group, a UKbased
adviser that works
with clients in more than
SINGAPORE AND TCF “
In March 2007, Singapore’s financial services regulator, the
Monetary Authority of Singapore (MAS), commissioned a poll to
assess consumer perceptions of whether financial institutions were
delivering fair dealing outcomes. The poll found that only 33.3% of
respondents were satisfied that a firm had consumers’ interests in
mind when selling them an investment product, with 59.5% saying
they were neutral and 7.3% dissatisfied. Similar results were
returned for the levels of after-sales and overall service standards
offered. It also found that the majority of respondents were not aware
of complaints-handling processes.
As a result, in February 2008, the MAS issued a consultation
paper on Proposed Guidelines on Board and Senior Management
Responsibility for Delivering Fair Dealing Outcomes to Consumers.
The guidelines, which were heavily influenced by the FSA’s
TCF initiative in the UK, emphasise the responsibility of senior
management in delivering fair dealing outcomes when providing
financial advisory services to retail consumers. The MAS expects
firms to review their business operations and to identify how well
they are delivering fair dealing outcomes. Where gaps exists, a plan
to address these gaps must be developed.
Similar to the FSA’s six outcomes for consumers, the MAS is
proposing five ‘fair dealing’ outcomes:
■ consumers have confidence that financial institutions put
consumers’ interests first in the conduct of their business;
■ financial institutions offer products and services that are suitable
for the consumer segments they target;
■ financial institutions appoint competent representatives who
provide consumers with advice that meet their financial objectives
and suit their personal circumstances;
■ consumers receive clear, relevant and timely information to make
informed investment decisions; and
■ financial institutions handle consumer complaints promptly and in
a consistent manner.
The consultation period is now closed and the MAS is reviewing
the comments submitted. The initiative has received the support of
trade bodies such as CFA Singapore, the local member society of the
global CFA Institute.
l Maintaining contact
Searle believes it is not
enough to make information
available to clients via
websites, for example, as
they often do not have the
time or the expertise to go
looking for it. He explains:
“People prefer to be spoon
fed. We produce what we
150 countries, also sees
TCF as an integral part of
its international strategy.
“There is nothing new
about TCF,” says Steve
Travis, international manager
at the group. “The
concept of treating customers
fairly is unchallengeable
and nobody can fail
to endorse it. But the new
INTERNATIONAL ADVISER [www.international-adviser.com] AUGUST 2008
initiative makes it clear the
FSA is now looking for firms
to do more than merely
comply with narrow and
prescriptive requirements.”
He adds: “The vast
majority of TCF has been
present in our culture for
many years. Our clients are
geographically mobile, so
it is imperative to have a
business model that can
be replicated internationally,
to provide a seamless,
high-quality service. We are
also constantly striving to
improve our service and
we believe TCF provides a
range of helpful signposts.”
l Setting out the rules
Travis believes creating
the principles at a regulatory
level is helpful for the
industry as a whole, as well
as the fact that the regulator
refocuses the concepts as
they develop. “Ultimately,
it is down to the individual
organisation to ingest these
into its culture because, in
practice, no two organisations
work alike,” he adds.
As to whether TCF is
growing as an international
practice, Travis says it is
difficult to comment specifically.
“In our view, there are
still too many non-UK based
organisations who take a
cavalier attitude to regulation
as a whole. This has
never been our approach.
We feel it is an advantage
for our head office to be
UK-based where regulation
has matured over the past
30 years and more.”
TCF, it seems, really is
something all adviser firms
should be doing in their
day-to-day business. Even
if a firm’s home regulator
does not at present impose
the TCF principles, it makes
sense at the very least to
think about what serves
clients best and, perhaps,
to adopt TCF as part of its
business practice.
The new initiative
makes it clear that
the FSA is now
looking for firms to
do more than merely
comply with narrow
and prescriptive
requirements
”
Steve Travis, international
manager, The Fry Group
KEY POINTS
Treating customers fairly was
established by the UK FSA
as a high-level principle in
2001. The TCF initiative is now
embraced in all its work with
customer-facing businesses.
Regulators and firms outside
the UK are increasingly
adopting the principles or the
spirit of TCF into their own
rules or business models,
although some jurisdictions
are ahead of others in this
respect.
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