A reminder to FSA authorised members that the FSA's TCF December deadline is fast approaching. The FSA set a December deadline for firms to demonstrate they are consistently treating customers fairly. For FSA authorised firms, this means:

• demonstrating that senior management have instilled a culture within the firm whereby they understand and can articulate what the fair treatment of customers means;
• ensuring this culture permeates all staff within the company and those staff know what their TCF responsibilities are;
• where errors are found they are put right and learned from;
• appropriately and accurately measuring performance against all customer fairness issues materially relevant to the firm's business and acting on the results;
• demonstrating that these measures are delivering fair outcomes; and
• have no serious failings, including areas of particular regulatory interest (of which we know SIPPs are).

The above points are extracted (and paraphrased in some cases) from various useful FSA documents that can be found on the website within the Treating Customers Fairly section. There is also some useful TCF information within the Small Firms section of the FSA website - this section has recently been redesigned and is a significant improvement on the previous layout.

Given that the FSA will be assessing firm's adherence to the December deadline in the first half of 2009, it really is worth reviewing the bullet points above within your firm prior to the year end.

Kevin Jack

Enhance Support Solutions Limited

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