The true value of TCF

By Nigel Alexander, head of bridging and commercial at Amicus 

Treating customers fairly is not only important, but critical to running a credible lending business. At Amicus, it is something we take very seriously.

So why is it so important to us in the lending industry? Aside from being generally good practice and, in many ways, common sense, the FCA is clear that all regulated firms (lenders and brokers alike) are responsible for making sure customers are treated fairly. There are six consumer outcomes that firms should strive to achieve to ensure the fair treatment of customers:

• outcome one: consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture
• outcome two: products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly
• outcome three: consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
• outcome four: where consumers receive advice, the advice is suitable and takes account of their circumstances
• outcome five: consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect
• outcome six: consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

All regulated firms must adhere to the FCA’s principles for businesses. Principle six states: ‘A firm must pay due regard to the interests of its customers and treat them fairly’. Both lenders and brokers have the same responsibility to demonstrate the fair treatment of customers.

Firms must pay regard to the interests of their customers and treat them fairly. All customer communications should be clear, fair and not misleading, and firms must ensure that their charging policy is clear and accessible.

How TCF works in action

In line with our commitment to continual improvement and having listened to feedback from stakeholders, Amicus recently carried out a thorough review of our customer-facing documentation. We did this to create a better customer experience with clearer language, more relevant information, less overall pages as well as giving our customers contact details and direct numbers for the team members at Amicus they may need to speak with. In short, we wanted to make sure our documentation gives the customer what they need to know in the clearest and most simple format possible.

In doing this, we improved layouts, provided clear information, less legal jargon and more clarity on the numbers part of the communication – ensuring transactions are easier to understand and calling out the overall calculation or balance so that it is clear to the customer at a glance.  

During the review and refresh process, we had the following objectives and key drivers in mind:

1. Consistency across product suites
   • look, feel, tone terminology
2. Transparency and accessibility
   • plain English, user-friendly layout, key terms, simplicity and concise
3. Operationally ‘smart’
   • least number of document variations, easy to maintain and standardise
4. Future-proofed
   • documents designed to accommodate the introduction of new products and mandatory changes.

Our new documents were introduced at the beginning of April 2018 and included updates to origination documentation (heads of terms, facility letters, tariff of charges and terms and conditions), redemption letters and post-completion letters. We also updated our solicitors’ and valuers’ instruction packs.

As these begin to roll out, we have been happy to hear views and comments from stakeholders to ensure we continue to communicate to customers in a way that provides them with all the information and support they need to make informed decisions about their Amcius loan.