Our latest insight looks at workplace pension providers’ Treating Customers Fairly (TCF) statements and charters, their internal TCF teams and how they measure customer feedback to ensure they are treating customers fairly.
The TCF principle aims to raise standards in the way firms carry on their business by introducing changes that will benefit consumers and increase their confidence in the financial services industry.
The regulator does not lay down any standard way in with TCF should be assessed and implemented and therefore it is down to individual providers to lay down their own framework to make sure there are TCF-related checks in place for product design, marketing, sales, customer support/information and complaints handling.
Our data shows that, other than Hargreaves Lansdown, all workplace pension providers have published a TCF statement and/or charter outlining their interpretation of TCF principles and values. These can be accessed by scheme members, employers and advisers and can be sent on request.
Other than Standard Life, all workplace pension providers have either a team or individual within their organisation that focuses on TCF. Advisers, members and employers all have access to this individual/team in order to ask questions about the workplace pension providers’ approach to TCF.
Hargreaves Lansdown leaves TCF to an individual. Whereas True Potential, Scottish Widows Master Trust, Scottish Widows GSIPP, Royal London, and Mercer Master Trust Scottish Widows have a TCF team.
Aegon Master Trust, Aegon Workplace ARC, Aviva Designer, Aviva My Money, Aviva My Money Master Trust, Fidelity, Fidelity Master Trust, Legal & General, Legal & General Master Trust, Mercer Master Trust Aviva and Scottish Widows have both an individual responsible for TCF and a TCF team.
All workplace pension providers have procedures in place to test staff understanding of TCF on either an annual or monthly basis. Only the IT team from Legal & General are not regularly tested.
For all provider staff there is a process to follow up where individuals do not demonstrate an acceptable level of understanding during which further training is identified for employees.
There is also a process to evaluate training outcomes for all providers. For example, for employees of Aegon Master Trust and Aegon Workplace ARC TCF training attendees have face to face discussions with trainers to assess their level of understanding post further training. They also resit one of the provider’s mandatory CBTs which covers the aspects of TCF.
Our data also shows that all workplace pension providers have a documented process to define how TCF should be taken into account in the product design process, and to demonstrate that products continue to meet the needs of clients.
All workplace pension provider consumer facing websites have also been check for TCF as well as compliance. For example, Royal London combines internal and external checks on a weekly basis to ensure continuous compliance with TCF.
When it comes to measuring customer feedback, workplace pension providers use a variety of online surveys, telephone surveys and focus groups. Telephone surveys are the most popular and are in use by all providers.
Overall, our data shows that workplace pension providers are working hard to demonstrate that they adhere to the principles of treating customers fairly.
It is, however, worth noting that Hargreaves Lansdown is the only provider that does not publish a TCF statement and/or charter outlining their interpretation of TCF principles and values to pension scheme members, employers, trustees and advisers. It is also the only provider to leave TCF as the responsibility of just one individual.
