Treating Customers Fairly | NatWest Intermediary Solutions


Treating Customers Fairly

Working together with TCF Info to make sure all customers are treated fairly

NatWest Intermediary Solutions recognises the importance of treating our customers fairly and are pleased to be working in partnership with TCF Info as one of 28 mortgage lenders who make up the TCF Lender Forum.


What is TCF Info?

TCF Info is a website offering practical guidance to mortgage intermediaries on how to implement the Financial Conduct Authority (FCA) principle of Treating Customers Fairly (TCF).



It offers tips on addressing customers in plain English as well as tools and templates for own branding and has been developed following research undertaken with over 300 mortgage intermediaries. The website is coordinated and managed by Frank Eve Consulting Limited and acts as a hub for TCF queries, tailored to the needs of intermediaries.

What are the principles of Treating Customers Fairly?

All firms regulated by the FCA have to support the FCA Handbook's principle to pay due regard to the interests of customers and treat them fairly. The TCF principle aims to raise standards by introducing changes that will benefit consumers and increase their confidence in the financial services industry.


Specifically TCF aims to:


  • Help customers fully understand the features, benefits, risks and costs of the financial products they buy.
  • Minimise the sale of unsuitable products by encouraging best practice before, during and after a sale.

What we want to achieve

The FCA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative.


These are:

  1. Consumers can be confident that they're dealing with firms where the fair treatment of customers is central to the corporate culture.
  2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly.
  3. Customers are provided with clear information and kept appropriately informed before, during and after the point of sale.
  4. Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard.
  6. Consumers do not face unreasonable post-sale barriers imposed by firms to change products, switch providers, submit a claim or make a complaint.

Treating Customers Fairly does not mean:


  • Creating satisfied customers – a satisfied customer could still be treated unfairly and not know it.
  • That every firm must offer an identical level of service – the FCA recognises that businesses have different resources and ways of doing things.
  • That the FCA has the final say on which products consumers should want or be sold.
  • That customers are no longer expected to make decisions or take responsibility for them.

TCF is a culture – doing business in a way that will help ensure customers get fair treatment.

TCF and your business

The FCA's Conduct of Business Rules support the principle of TCF, so if you're following the rules relevant to the mortgage industry, you're probably already implementing TCF in much of what you do.


However, in order to satisfy FCA requirements, you'll  need to take extra steps to show how you're implementing TCF throughout your business.

Assessing and implementing TCF

The FCA doesn't lay down any standard way in which Treating Customers Fairly should be assessed and implemented, but it has highlighted key areas where it's a good idea to have extra checks in place.


These include:


  • Product design.
  • Financial promotion and marketing practices.
  • The sales process.
  • Information and customer support after the point of sale.
  • Complaint handling.

In practice this means identifying potential gaps in TCF practice and developing procedures and checks to plug these in the following areas:


  • Staff training and awareness of TCF.
  • Sales and marketing material.
  • Product understanding.
  • Advice and sales process.
  • Fact find and flow of information to the client (including after-sales).
  • Complaint handling.
  • Remuneration and incentives.
  • Risk assessment of TCF non-compliance.
  • Record keeping and management information.

Further resources

TCF Info has produced a number of tips and tools to help you focus on what you need to do, including information on deadlines and monitoring, principles checklist, case studies and latest news.

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