The Financial Conduct Authority launched its “Treating Customers Fairly” (TCF) initiative as part of a wide ranging move away from prescriptive rules and regulations, to a more “principles-based” approach. In particular TCF is geared towards delivering one of the FCA's key aims and objectives - “helping retail consumers achieve a fair deal.”
FCA Rules have always required fair treatment of customers. The FCA “Principles for Businesses” include Principle 6 - “A firm must pay due regard to the interests of their customers and treat them fairly”.
TCF however, requires regulated firms to demonstrate more formally that fair treatment of their customers is fundamental to their everyday operations, and to set out measures and processes to evidence that fair treatment of customers is being delivered.
Statement and Policy on Treating Customers Fairly
Capital Fortune Ltd. has always placed a strong emphasis on providing the highest standards of customer service.
We believe that our existing and potential customers' satisfaction is essential to our business model. Customers who feel they have been treated well are likely to refer their friends and family to us as new customers. Those customers, in turn will refer us if they are satisfied by our service levels.
However, we appreciate that because a customer is satisfied, it does not necessarily mean they have been treated fairly.
We therefore regularly review our business practices to ensure that we not only deliver exceptional customer service, but we also make certain that our customers receive a fair deal.
Senior Management Responsibility
Senior management of a regulated firm are responsible for ensuring that fair treatment of customers is central to the firm's culture and everyday operations.
The directors and managers of Capital Fortune Ltd. will therefore be responsible for delivering this fair treatment to the company's customers and ensuring that all staff have the customer's best interests at the forefront of their minds at all times. The Directors will report regularly on progress with TCF to the Board and the Strategic Advisory Committee.
Failure to deliver consistently fair treatment to customers is likely to be seen by the FCA as a failure by the company's senior management to implement adequate systems and controls.
What does TCF mean to Capital Fortune Limited?
In the context of our business which provides advice on mortgages, general insurance and pure protection products, primarily (but not solely) to private customers, we have identified the following objectives that we believe will deliver fair treatment (as distinct from “good service”) to Capital Fortune customers.
1. We will work at all times, in your best interests by ascertaining your individual needs, preferences and circumstances, then supplying information and advice on mortgage and/or insurance products which meet them.
2. We will ensure our advisers are fully trained and rewarded based on their knowledge, the quality of their advice, their customer service, as well as the amount of business they produce.
3. We will provide our full Initial Disclosure Document as soon as is practicable after our initial contact. The Initial Disclosure Document describes our services and the fees we charge, allowing you to decide whether our services are right for you.
4. We will only recommend a mortgage that we consider the most suitable for you and that you can afford. We will not recommend a mortgage product if we are not satisfied that it is both suitable and affordable.
Clear and Understandable Information
5. We will provide full details of our advice and recommendations, and any charges we have agreed in advance with you, in a written report within 5 days of the mortgage or insurance application being submitted.
6. We will consistently make ourselves available throughout the application process and at any other time post-application always giving you the most accurate, current information and advice on available products.
7. We will update you within 24 hours of any adverse decision and to immediately provide all the alternative options.
8. We will answer 99% of telephone calls 24 hours per day, 7 days per week. A qualified Capital Fortune Adviser will contact you within 4 hours of your received call between Monday and Friday 9am - 6pm and within 48 hours of your call if made outside of these hours.
9. We will ensure that all communications and promotional material we issue (including our website and email communications) are clear, fair, not misleading and relevant to the recipient. We will provide all our documentation in plain language and refrain from all jargon in our dealings with you.
10. We will endeavour to provide first class customer service to you and in the unlikely event that our professional standards fall short, work with you to resolve the situation as soon as possible.
11. We will offer our full and professional services to you and your family at any time you choose, by providing on-going reviews of your mortgage and insurance needs.
12. We will value the personal information you provide and to take all reasonable measures to guarantee the confidentiality of that information and protect it from access by any unauthorized third parties.
13. You have the right to inspect the personal information we hold about you and we will make this available on request subject to the applicable legal requirements.
Independence of Mortgage Advice
14. We will provide mortgage advice in a totally impartial manner and will act in your interests throughout the mortgage application
15. We will resolve any issues quickly for you but in the event you wish to make a formal complaint, this will be appropriately dealt with by our mortgage network HL Partnership. The contact details for our mortgage network can be found on your Initial Disclosure Document. In the event that you are not satisfied with their response to your complaint, they will provide full details of the Financial Ombudsman Scheme, who will determine the dispute in an impartial and independent manner.
16. We will request your feedback by sending a satisfaction questionnaire to a random sample of customers within 28 days of their mortgage completion. We will publish all customer satisfaction results received on our website which will be updated on a regular basis.