Treating Customers Fairly
TCF Outcome 1 speaks to the principle of Culture & Governance.
- Customers must feel confident that they are dealing with an institution where TCF is at the core of their culture.
The TCF principles are encompassed in the TCF outcomes and in many ways are also embodied in the General Code of Conduct.
TCF Outcome 2 speaks to the principle of Product Suitability.
- Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly.
FSCA Question: Do you understand your clients, their financial situation and their financial needs?
“Section 8 of the General Code of Conduct obliges advisors to gather as much information from the client as possible and thereafter conduct a financial needs analysis before making any recommendations. In addition, section 9 of the General Code of Conduct safeguards both the advisor and client by stating that a detailed record of advice must be kept about the recommendations that were made based on the analysis conducted. This must include all products considered and details about what was eventually implemented. For example, if a client requested a certain product, it is in the record of advice that you would need to explain why this product is perhaps inappropriate to the client’s needs and objectives.” – Masthead newsletter
TCF Outcome 3 speaks to the principle of Disclosure.
- Customers are provided with clear information and kept appropriately informed before, during and after point of sale.
FSCA Question: Do you use clear explanations of the products when talking to your clients?
“The General Code of Conduct prescribe that information provided to a client must be factually correct, in plain language, and must be adequate and appropriate in relation to the level of knowledge of the particular client. In addition, disclosures made to a client should be reduced to writing. The client must also be informed of all relevant monetary obligations, which includes fees and charges to the product supplier and commissions and/or fees that will be paid to the financial advisor or intermediary.” – Masthead
TCF Outcome 4 speaks to the Principle of Suitable Advice.
- Advice is suitable and according to the customer’s circumstances.
“Section 8 of the General Code of Conduct also requires that advice must be suitable. In terms of section 8 of the General Code of Conduct an advisor must take reasonable steps to seek appropriate and available information from the client regarding the client’s financial situation, financial product experience and needs and objectives in order to provide the client with appropriate advice.
This information must be analysed in order to identify a product that will be appropriate for the client, taking the client’s risk profile (if applicable) and financial needs and objectives into account. Any shortfall in a client’s financial circumstances should be highlighted to the client. – Masthead
FSCA Questions: Did you conduct a suitability analysis in terms of section 8(1)(c) of the General Code?
Did you check the client’s needs against the recommendations?
Does your record of advice comply with the General Code of Conduct and contain all the required disclosures?
Do you consider all requirements relating to the replacement of products?
TCF Outcome 5 speaks to the Principle of Performance and Service in line with expectations.
- Service is of an acceptable standard and products perform as customers have been led to expect.
“This outcome places a responsibility on product providers who are creating the products. However, it is a responsibility shared with the advisor as it is based on what information is given to the client and what was disclosed in this regard. Providing clear information to a client in a manner in which the client understands will ensure that the client’s expectation is aligned to how the product should perform. The requirement that advice and products must be suitable also plays a significant role in meeting this outcome due to the fact that unsuitable products will certainly not perform in line with the specific needs that the client may have.” – Masthead
TCF Outcome 6 speaks to the Principle of Claims, Complaints and changes.
- Customers do not face unreasonable post-sale barriers when they want to change a product, switch providers, submit a claim or make a complaint.
FSCA Questions:
When you provide after-sales service, is it easy for clients to contact you for assistance?
Do you make it a priority to assist clients who have complaints?
Do you help clients when they contact product suppliers for any service after contracting?
Brolink to provide feedback to Insurance Companies within the following timelines:
- Social Media complaints – 2 hours
- Executive Complaints – 1 hour
- Insurer Complaints – 8 hours
- Short term Ombudsman complaints – 5 days
- Fais Ombudsman complaints – 5 days
- Banking Ombudsman complaints – 5 days
- Direct client complaints (via email or telephone) – 4 hours
You are encouraged to complete the assessment form by the 15th of July, demonstrating your knowledge of TCF.
A certificate will be awarded to those who pass the assessment.
Access the assessment form here
