Treating Customers Fairly | TAG

Policy statement on treating customers fairly (TCF)

The aim of this statement is to detail the Firm's policy with regards to FSA principle 6;

"Pay due regard to the interests of its customers and treat them fairly" and the processes of putting customers' interests at the heart of the business.

General Risk Assessment:

The firm is committed to the rules and general principles of the FSA and being a small firm has close links with its clients. There is a generally low flow of complaints which tend to be in regard to endowment mortgages that relate to business conducted in the mid to late 1990's. This is not reflected in today's working practices and we have received no complaint in regard to general business conducted in the last three years.

We have excellent recording and administrative systems and regularly review staff and adviser competence.

Client care and how we treat individual clients are reviewed regularly, particularly where there is any evidence of client misunderstanding regarding the firm's services, systems and advice process. Good communication with our clients provides a better understanding of their planning requirements and ultimately builds trust between client and the firm. The firm's remuneration structure is regularly reviewed to ensure that it does not cause any conflicts of interest.

All of the above, in TAGs case embodies TCF and why we assess TCF risks as being low.

Financial promotions, reports and suitability letters: It is the policy of the firm to attempt to make all correspondence and promotions with clients clear, concise, simple, fair and not misleading. Whilst suitability letters/ reports can be lengthy at times, in order to explain the benefits, risks and potential disadvantages associated with recommendations, we attempt to make them as easy to understand as possible. The firm does not engage in financial promotions.
Advice and sales process: We do at all times ensure that advice is appropriate and that due account has been taken of the client's specific profile, needs, knowledge and attitude to risk. When assessing our client's attitude to risk we will ensure that our client understands what that risk means in our client's terms. [We now advocate a risk profiling exercise for each of our clients].

We will always obtain enough client information to understand their circumstances, income, expenditure, affordability, needs and wants both now and in the future.

By updating client information and regularly updated fact finds where possible, we will advise clients of needs that they may not be aware of and structure a programme over time to protect client's exposure to risks and capitalise on opportunities via sound financial planning. We will then give our clients the option to act upon these needs or reject them if they wish without pressure to proceed.

We will always ensure that we disclose information in a way that is understandable to our clients whilst complying with FSA rules and requirements. This particularly applies to the potential risks clients take when investing.

We always ensure fair treatment.

If policy exclusions or charges apply we will bring these to our clients attention without prompting and explain their effects to our client either in a client meeting or where required or requested in writing.

Flow of information between the firm and its clients: It is important that clients understand the nature of the services being offered by the firm and how they pay for them.

The firm is a fee and commission practice and we will always agree a fee or costs before commencement of work. If additional charges are to be incurred then we will always agree and explain these to the client before carrying out the work. If the client wishes to pay for their fee by allowing us to retain any commission payments, we will offset such amounts against our fee and always refund any difference to the client. If we intend to retain excess commission we always obtain the clients consent. We will maintain adequate records to account for client monies and invoices raised.

We will always be open with our clients and will, if necessary where clients are paying an agreed retainer for this service, communicate with them on matters that might effect their planning.

Accurate and timely record keeping: it is important that we keep accurate and adequate records of customer profiles and instructions at each stage of the sales process. It is also important that administration is carried out efficiently and accurate records are kept to record all advice and information given and received.

If a client requires information we will be open and responsive to their request, responding in a timely manner. We will be mindful of the need to review client information to ensure its accuracy and to comply with the data protection act. This will enable us to respond fairly to our clients but will also maintain an accurate evidential trail in the unfortunate event of a customer dispute.

At all times we will ensure that client data remains confidential.

Disputes and complaint handling: We already have a written complaints procedure that every member of staff has read and signed off and that they understand. It is important that disputes are handled sympathetically and objectively and that the firm is open and honest where it has made mistakes. We recognise that a well-handled complaint can prevent the situation escalating and ultimately retain customer loyalty.

We should be open in our complaint handling and inform clients of areas outside of their complaint where we may have discovered errors of which they may not be aware, as this is inline with FSA guidelines on TCF. A complaint does not automatically lead to compensation. Putting the matter right and offering an apology may often be more than enough. Clients readily accept that errors occur and in many cases are gratified that a firm will accept that they are fallible and are keen to rectify the situation.

Staff training: We acknowledge that all staff impact on whether customers are treated fairly and having members of staff who are adequately trained and mature enough to acknowledge whether a task is outside their expertise is important. Continuing personal development is important for all members of staff to maintain skills and competence, but we are also aware of the limitations of training offered by product providers and do not rely on them. We encourage our staff to obtain professional examinations and encourage them to consider on how such qualifications can then be utilised in helping our clients.

Information from product providers: it is important that staff understand and take into consideration documentation supplied by product providers. Not only is it important that staff understand the features and risks associated with recommended products but also can explain them to clients in a manner that they will understand whilst advisers are certain of their suitability. Staff should also be able to make and informed judgement on the content and opinions expressed in providers literature.

Keeping up to date: the Senior Management will endeavour to monitor further guidance from the FSA, with the aim of ensuring that TCF is consistently built into the operating model and overall culture of all aspects of the business at all times.