Altus

For the last few years the FSA has been signalling a shift towards principles based regulation but TCF is the first real concrete example. With no rigid rules to stick to, TCF places a new kind of compliance challenge on Financial Services firms. Now they have to not only demonstrate compliance with rules but to formulate them in the first place. 

Altus have worked with several clients undertaking TCF compliance programmes and have recognised that there are some key ingredients to a successful TCF implementation:

• Carefully analyse how TCF principles relate to your own business (considering products, market segments and sales channels) and to your partners (e.g. brokers, intermediaries and outsourcers).
• Define a set of measurable rules that demonstrably support the six TCF outcomes and add these to your existing governance – Altus can help build an explicit Business Constraints Framework to implement this.
• Review (and revise) your current business processes against these rules from a customer perspective – Altus Viewpoint Charts provide a great way to visualise the customer’s experience.
• Use the same rules to define a code of practice for partner organisations and ensure that this is incorporated in your outsourcing agreements.
• Define the information required to evidence the measures identified above and develop the necessary MI capability to provide this.
• Embed TCF compliance in your project governance process – and ensure this is formally documented in the same way you would a BAU process.

By following our systematic, step-wise approach to business architecture, Altus can help you with any or all of these steps – see the Services and Case Studies links for more details.