Treating Customers Fairly (TCF)

An overview of TCF

Why treat the customer fairly? The irregularity of information between retail financial services consumers and financial institutions means that financial services consumers are particularly vulnerable to unfair treatment. Typically, financial institutions have far more expertise and resources available to them in designing, distributing and servicing financial products than consumers have available to them in making decisions about financial transactions. The nature of financial products and services is such that, in many instances, the consequences of unfair treatment or poor decisions are only felt some time – in some cases many years – after transacting. Significant hardship can be the result. In Namibia, challenges are worsened by low levels of both basic and financial literacy, increasing the risk of consumer exploitation.

TCF is a regulatory approach that seeks to ensure that specific, clearly articulated fairness outcomes for financial services customers are demonstrably delivered by regulated financial institutions. The further intention is that delivery of these specific outcomes will in turn ensure the supply of appropriate financial products and services to customers and enhanced transparency and discipline in financial institutions, resulting in improved customer confidence. The final desired outcome is that customers’ financial services needs are appropriately met through a sustainable industry. It is proposed for the six Treating Customers Fairly (TCF) outcomes to be introduced in Namibia.

These are:

1. Consumers should be confident that they are dealing with firms where fair treatment of customers is central to corporate culture
2. Products and services marketed and sold in the retail market should be designed to meet the needs of identified consumers.
3. Advice should be suitable and take account of the consumer’s circumstances.
4. Consumers must be provide with clear information and kept informed before, during and after the point of sale.
5. Consumers should be sold products that perform as firms have led to expect, within reasonable limitations.
6. Consumers should not face unreasonable post-sale barriers imposed by firms to change products, switch provider, submit claims or complain.

These outcomes are to be demonstrably delivered throughout the product life cycle, from product design and promotion, through advice and servicing, to complaints and claims handling – and throughout the product value chain. In summary, all financial institutions regulated by NAMFISA in time, will be under TCF scrutiny.

“A customer is the most important visitor on our premises, he is not dependent on us. We are dependent on him. He is not an interruption in our work. He is the purpose of it. He is not an outsider in our business. He is part of it. We are not doing him a favour by serving him. He is doing us a favour by giving us an opportunity to do so.” _Mahatma Gandhi

TCF is a regulatory approach that seeks to ensure that specific, clearly articulated fairness outcomes for financial services customers are demonstrably delivered by regulated financial institutions.
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