Minimum standard 8. Training
Have we taken steps to ensure that staff are aware of TCF and how it affects their role?
Yes, we have presented our TCF policy to staff, including back office staff, and they are aware of TCF and have access to this webpage. We will communicate our TCF vision to all staff. We will ensure staff understand it and what it means for them in their day to day jobs. TCF will be regularly discussed at staff meetings.
To test the staff's understanding of what TCF means for them we will them send a TCF questionnaire. Results of the questionnaire will be reviewed and any gaps will be rectified. We will proactively encourage staff to give feedback on areas they felt could be improved to deliver TCF.
What steps have we taken to ensure that advisers maintain an up to date knowledge of the products available in the market?
To ensure that we are satisfied that staff have the necessary training, skills and competence we:
Ensure they have the appropriate industry qualifications when joining us
Take an appropriate internal exam for each product they intend to sell
Observe new advisers during their first few meetings with clients. We observe the adviser’s interpersonal skills during a meeting with clients, e.g. listening skills, questioning technique, dealing with objections, and discussing the features and benefits of products. We then give the adviser an overall assessment by stating whether the presentation was competent or not. If not, we set up a Development and Action Plan and a timescale. After this we establish whether non-competent areas have been rectified, whether there are any further training needs and whether a further review is required.
How have our training and competency requirements developed to implement TCF?
If TCF indicates that our procedures and T&C manual require updating or amending then we will do so.
We ensure that advisers have a full understanding of all of the features of the products within their range, and will be able to use this understanding to match the needs of client’s to the most appropriate product.
All of these elements are tested on a routine basis and adequate levels of monitoring are undertaken to establish that the correct sales processes are being followed in a practical sense.
Management and advisers' focus on the quality of training rather than achieving 50 CPD hours per year. We will conduct an annual training needs analysis for each adviser for the year ahead. This will analyse MI / KPI statistics and plan a CII exam schedule.
Gap Analysis for Minimum standard 8
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 9. Product Providers and the information they issue
Do product providers provide enough assistance to us, e.g. product information and training, technical support?
Yes. We understand the features and risks associated with the products we handle. This enables us to explain the products adequately to clients and ensures that we are certain of their suitability.
Do the product providers we deal with provide a good service to clients that is consistent with TCF principles?
Yes. We make an informed judgement on whether we agree with opinions expressed in providers’ literature.
Do we feel that any inducements or business incentives offered to clients by product providers are fair?
Yes. We form a judgement about whether the material issued by product providers is suitable for use by our clients.
Do we consider TCF issues when deciding which products should be included in our range?
Yes
Do we provide feedback to product providers on TCF issues?
Yes
Gap Analysis for Minimum standard 9
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 10. Accurate & Timely Record Keeping
Are our records adequate and readily available to ensure an efficient service can be provided to clients?
Yes. We maintain adequate records of client profiles and instructions, and on each stage of the sales process. We can then respond fairly when disputes arise, and will help if we have to provide evidence to the Financial Ombudsman Service (FOS).
Gap Analysis for Minimum standard 10
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 11. Disputes and Complaint Handling
Management carried out an analysis of each complaint to establish if there is anything which points to a weakness in our processes.
We conducted an analysis of the root causes of any complaint we receive.
If, after a complaint investigation, we discover a training need for an adviser in relation to information gathering for sales (e.g. of sub prime mortgages) we will introduce training for all advisers.
Staff are trained on how to identify a complaint and what to do if a complaint is received.
Have we made appropriate arrangements for complaints to be handled in a prompt and impartial manner?
Yes. We have a Complaints Procedure, which is free to clients. We attach importance to the fair and effective resolution of complaints. Our Compliance Director (and not the adviser responsible for the original advice) is responsible for handling complaints.
We endeavour to resolve any disputes or complaints ‘in-house’, but if this is not possible you may be entitled to refer it to the Financial Ombudsman Service. Their service is free to consumers. We aim to handle complaints fairly
Where complaints are upheld, we seek to ensure that clients are compensated appropriately. We ensure that claims and service issues are processed in a timely manner.
How do we identify trends and remedy issues arising from our handling of customer complaints that may indicate a wider or recurring problem?
Fortunately, we have very few complaints so it is difficult to identify trends. However, if there were trends we would address them.
What targets do we set for Complaint Handlers?
This is set out in our Complaints Procedure
How are lessons from complaints shared between different business areas?
Fortunately, we have very few complaints. However, if there were we would learn lessons from them and share lessons between different business areas via email or quarterly meetings.
What is done to ensure the outcome offered to customers is full and fair?
By following our Complaints Procedure and discussing our responses with our PI insurers.
We carry out an analysis of each complaint to establish if there is anything which points to a weakness in our processes.
We conduct an analysis of the root causes of the complaints we received. If these reveal a training need for several advisers in relation to information gathering for sales of sub prime mortgages then we will introduce training for all advisers.
We train our staff on how to identify a complaint and what to do if a complaint is received.
We have complaints procedures and can tolerance complaints.
Advisers do not bury complaints.
Advice on high risk products is restricted to a small number of specialist advisers.
Gap Analysis for Minimum standard 11
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 12. Risk Assessment and Mitigation
Have we developed a TCF strategy for the purpose of identifying any TCF risks?
Yes. We endeavour to ensure that we still review all aspects of our business and organisational structures to identify risks that might have an impact on our ability to treat clients fairly. We will then act to mitigate any such risks. We endeavour to ensure that we have a high level of control over our advisers and Appointed Representatives.
Has responsibility for ensuring clients are treated fairly been allocated to a senior individual within our firm?
Yes, the Compliance Director
Gap Analysis for Minimum standard 12
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 13. Flow of information
Do we seek to gather feedback from clients of the services provided?
Yes. There is a flow of information between ourselves and our clients. We endeavour to ensure that our clients remain clear about the nature of the services that we offer and that the flow of information between the client and us remains less formal. We ensure that an effective flow of information to clients (including verbal discussions) is maintained and recorded on our back office system, Adviser Office from 1st software. We also conduct random customer surveys to check their experiences.
How do sales people ensure customers understand the risk and limitations of a product as well as its benefits?
By issuing illustrations and Suitability Letters, which they sign to confirm their understanding.
What processes and checks are in place to ensure records are kept of discussion and communication with customers?
Our Back Office System, Adviser Office keeps records of client conversations and documentation given to clients. Compliance Director conducts selected checks.
Gap Analysis for Minimum standard 13
Specific milestones to be achieved
By December 2008 we will be able to demonstrate that we are consistently ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
Minimum standard 14. Management Information, Responsibilities, Strategy & Reporting
All relevant information, collected during the course of day-to-day business, from whatever source, can be described as ‘Management Information’.e.g. customers, customer treatment, staff, calls, visits, meetings, opinions, predictions, IFA feedback, Press coverage.
Do we have management information to show that we are treating our customers fairly?
Yes, as shown below.
Have we identified TCF indicators on which management information should be gathered to measure our performance with TCF principles?
Yes, the methods of monitoring / statistics we produce include:
KPIs
Persistency rates / records
Compliance monitoring reports
Performance against defined standards (including any incentive schemes in operation)
Sales
Checks on sale documentation
Complaints, their levels and trends (data for both customer and other)
Customer surveys / feedback, i.e. random customer surveys to check their experiences of dealing with us. We welcome customer feedback and would be grateful if you would take the time to complete an online customer survey and add any comments you feel necessary. These surveys are a way of differentiating between a satisfied customer and one that has been treated fairly.
Accompanied sales meetings
Internal exams
Are we able to produce accurate and frequent management information that will enable compliance with TCF to be monitored?
Yes. The Compliance Director achieves these objectives by monitoring persistency quarterly, complaints on an ongoing basis, and sales on a weekly basis. We report our progress on a regular basis to ensure we achieve the required standards. We provide details of activities undertaken to measure performance, and action either undertaken or under progress to address any deficiencies. Having the appropriate Management Information (MI) will help us know if we are delivering our strategies and help us to identify gaps where further work is needed.
Our client relationship cycle
We keep clients properly informed during the course of an ongoing relationship by conducting regular reviews and producing valuation reports. We endeavour to ensure that we always act with integrity in our dealings with clients, regardless of the length of the relationship and regardless of how often they transact repeat business.
How is the requirement to treat customers fairly included in performance measures, objective setting and rewards for staff?
Key Performance Indicators (KPI) are presented to all relevant staff at quarterly meetings to enable them to:
Understand their own performance
Provide information regarding the interface with customers
How does our record keeping enable us to demonstrate whether we have met our TCF obligations? How is that information shared with others in our firm?
Procedures are shown on online company manual. Records and statistics are produces by Adviser Office reports, kept on our server, and shared with advisers and directors via email and quarterly meetings.
How have you included TCF into the way you run your business and your firm's values?
Our T&C manual incorporates TCF requirements
How do you assess whether you are treating your customers fairly, and how is this reported to management?
By following TCF procedures and our T&C manual. Any breaches are reported to directors and addressed. Where we find gaps against TCF we fill them.
What changes could you make to your organisational structure or to services/products offered to support TCF?
None required
How are you engaging, motivating and training all of your staff on TCF?
Everyday activity, Email bulletins
How does your firm measure the understanding of TCF by staff?
Staff internal exams will be conducted
How does your firm's management indicate their support of TCF?
Our T&C manual and the TCF page of our website
Management Information (MI) downloads:
MI guide
MI assessment
Guide to monitoring the quality of advice
Monitoring the advice given
Gap Analysis for Minimum standard 14
Specific milestones to be achieved
By the end of March 2008 we had appropriate Management Information (MI) and measures in place to test whether we are ‘Treating Customers Fairly’.
How the findings are used
To amend our procedures so that we can test whether we are ‘Treating Customers Fairly’.
Date reviewed and updated
Ongoing
How we benchmark against the six consumer outcomes
By following our procedures we satisfy the consumer outcomes required.
