An Implementation Guide for TCF Guidelines for Insurance Brokers

The Financial Conduct Authority (FCA)’s Treating Customers Fairly (TCF) guidelines apply to every financial services provider that they regulate.

In this post, we’ll discuss how insurance brokers can implement these TCF guidelines through exploring the six outcomes that the FCA wishes to result from their initiative.

What is the TCF Initiative?

The FCA’s TCF initiative is designed to deliver six improved outcomes for any customer who considers, compares, purchases, or renews certain financial products and services. In a paper introducing the initiative, the FCA said that they now expect firms to make TCF “an integral part of their business culture.” They also highlighted that TCF is an ongoing process. “It is not something that firms can implement and then forget about.”

This means that demonstrating your commitment to TCF, and evidencing how your firm is implementing it, will play a part in securing and maintaining your FCA authorisation.

The FCA’s TCF initiative is designed to deliver six improved outcomes for any customer who considers, compares, purchases, or renews certain financial products and services

The 6 Treating Customers Fairly Outcomes

  1. Customers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
  2. Products and services are designed to meet the needs of identified consumer groups and are targeted accordingly.
  3. Customers are provided with clear information. They are also kept appropriately informed before, during, and after the point of sale.
  4. Whenever customers receive advice, the advice is suitable and takes account of their personal circumstances.
  5. Customers can access products that perform as firms have led them to expect. The associated level of service is of an acceptable standard, and also in line with what they have been led to expect.
  6. Customers do not face any unreasonable post-sale barriers to submit claims, make complaints, switch providers, or change products.

How Insurance Brokers Can Implement TCP Outcomes

Let’s examine each of these outcomes in turn, to assess how they’d look in practice for insurance brokers.

Outcome 1 – Placing Fair Treatment of Customers at the Centre of Your Corporate Culture

How can you measure a corporate culture? You cannot. It’s intangible – the sort of thing one simply “feels” when they interact with your company in any way.

Yet the TCF guidelines require you to evidence how fair treatment of your customers is at the centre of your corporate culture. The key to this is total transparency. You need to provide comprehensive and continuous proof that your company is doing exactly what it says it’s doing. So in short, you need to walk the walk, and not just talk the talk.

Audit and Review

This might require an audit of every aspect of your business – including your employees, your products, and your processes. Review everything through the lens of fair treatment for customers.


As part of the actions you take, you might run training sessions for employees on the TCF principles. Make this training a regular part of your onboarding experience for new employees and conduct periodic refresher courses to demonstrate your ongoing commitment to TCF.

Make Records

Make sure you assess and record every initiative you undertake when reviewing your corporate culture, so that you will always be able to evidence the lengths you go to.

Outcome 2 – Meeting the Needs of Identified Consumer Groups and Targeting Them Accordingly

Audit Products and Services

Conduct a thorough audit of your products and services. Ask yourself – who are they made for? Who are they aimed at? And who are they most beneficial to?

Consumer Research

You may need to revisit your consumer research, to establish once again who your customers are, what they need, and how your products and services can help them. And you may need to conduct fresh research periodically, to demonstrate that you’re responding to a changing market. For example, have you reviewed your products since the UK went through its “cost of living crisis”, to ensure that your customers can still afford what you have to offer?

Staff Training

Staff training can also play a role here. You need to ensure all of your employees, particularly your sales specialists, are more concerned with meeting customer needs than they are with simply making sales. You should also review your marketing, to ensure that you’re being as clear as possible with every product or service you sell.

Outcome 3 – Providing Customers With Clear Information and Keeping Them Informed

Review Communications

Assess the clarity of your communications at every possible customer touchpoint. Is everything concise and easy to understand? Do you effectively communicate all possible charges and fees?


Once again, your employee training could focus on clarity of communication. You might train your sales staff to avoid using acronyms or buzzwords, for example. And you could train your support staff to listen carefully before they offer advice, so as to be absolutely sure they’re adequately meeting each customer’s unique needs.

Consider the Entire Journey

The TCF guidelines are intended to apply to the entire customer journey – “before, during, and after the point of sale.” For insurance brokers, this “during” and “after” could last for years. Your customers should expect total clarity and transparency when they first buy your products. They should expect the same standard of service when they call you for claims support five years later.

Outcome 4 – Providing Suitable, Customer-Centric Advice

This outcome is particularly important for insurance brokers, for whom offering advice on risk management and insurance products forms a core part of business.

Customers Come First

Your central ethos should be that any advice you give is given purely in the customer’s best interests, and never for the company’s gain. And you should apply this ethos to every possible customer touchpoint – because whenever and wherever customers interact with you, they may ask you a question, which might require you to give advice.

Staff Training

Any staff working in any role that sees them interacting with customers, either directly or indirectly, should receive full training on the importance of meeting customers’ unique needs. They should also have access to any information they’ll need to provide suitable advice, and where this information isn’t available, there should be a clear line of reporting for escalating or referring cases.

Outcome 5 – Ensuring Products and Services Perform in line of Customer Expectations

Review Products and Services

Review your products and services, and all of your marketing channels. What promises are you making, and does everything that you offer deliver on these promises? Customers should never receive any nasty surprises after they start, or finish, working with you.

Introduce Consistent Product Quality Auditing

Remember that the FCA considers meeting TCF guidelines as an ongoing process. So you should have a constant and consistent product quality management and auditing process in place, one that repeatedly measures your offering against your business’s objectives.

Collect Customer Feedback

A good way to evidence your commitment to this outcome is through collecting customer feedback wherever possible, and through acting on any feedback you receive. Make a point of asking customers: How did we do? And are there any areas where things did not really work like you thought they would?

Outcome 6 – Removing Post-Sale Barriers to Making Claims, Submitting Complaints etc.

This is all about providing comprehensive and accessible post-sale support to customers. Most insurance brokers offer some kind of claims support service, alongside some kind of ongoing insurance advice.

Assess Your Claims Support Resources

You need to ensure that you can deliver on all of the promises you make to your customers at the point of sale.

This might be a question of assessing where you currently invest your resources. If your company’s preoccupied with profits and growth above all else, then you might invest the majority of your resources into sales and marketing. But to meet this TCF outcome, it’s vital that you invest just as much – if not more – into customer support.

Review and Streamline Your Complaints Procedure

This outcome extends to the actions you probably don’t want your customers to take, such as making complaints, changing products, or switching providers. You need to make it as easy as possible for customers to do any of these things.

Obviously, nobody likes getting complaints, and nobody likes losing customers. But consider this: If you commit to all of the TCF outcomes, then your customers should be so satisfied with your services and support that they wouldn’t dream of going elsewhere!

Further Support For Insurance Brokers

You’ll find numerous guides on our site to the various aspects of FCA authorisation, and your required conduct:

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