The Kirk Consultancy


"Thank you for all your efforts and indeed for the extensive work which has gone into delivering this important project. This is already making a real difference to the way that firms behave, which is fantastic."
Managing Director,
Financial Services Authority

We are proud to have advised the Financial Services Authority, leading retail financial services groups and industry trade bodies on this priority issue.

The principle of treating customers fairly (TCF) aims to raise standards in the way firms set strategy, design products and deliver customer experiences. It places fairness at the core of strategy and culture to benefit consumers and increase their confidence in the financial services industry.

Advising The FSA
Tim Kirk has been a close adviser to the Financial Services Authority (FSA), helping it to develop approaches to assess fairness, regulate in a outcome-based environment, communicate with the industry, and drive change across the industry. This has included. more »
  • Advising on how to assess firms' performance against the December 2008 deadline and how to include TCF within the ARROW assessment process.
  • Developing FSA publications and documentation to communicate TCF requirements and good practice.
  • Developing and delivering TCF training for FSA supervisory and enforcement teams.
  • Speaking at the FSA's seminar to help firms understand the requirements for TCF Management Information.

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TCF Current State Assessment Diagnostic Tool
Drawing on our work advising the FSA, and insight gained from world-class companies and leading FS companies (including those that have passed previous FSA deadlines), we have developed a proprietory methodology to assess firms' TCF performance. more »

Our TCF diagnostic provides:

  • A board-room to boiler room assessment of TCF performance.
  • A crucial focus on both the quality of processes to deliver fairness, and the outcomes delivered to customers.
  • A modular approach can be applied across the whole business, or to specific functions, customer outcomes, processes (e.g. telesales, complaints handling) or key risk areas (e.g. management information, customer communications, complaints).

Clients benefit from an assessment that considers performance against the key risks to customers being treated fairly, and provides a clear articulation of areas of strength and areas that pose a risk to being able to demonstrate that customers are being treated fairly.

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Support to Firms
Our TCF work with clients centres on developing a business-led response to meeting the FSA's requirements by embedding TCF into good business practice. In helping clients respond to TCF, we draw on our research and work with world-class companies from outside the FS industry. Our TCF work has included: more »
  • TCF Embeddedness Assessments:  We have assisted major retail groups to conduct full assessments of their progress and performance against the December 2008 deadline to consistently treat customers fairly. Our work has covered Life, General Insurance and Asset Management businesses, with reports from our assessments submitted to the FSA.
  • Management Information:  We supported a global financial services company to develop a customer dashboard and to build customer and TCF MI into business-as-usual governance and decision making up to Board level. We have conducted full assessments of the quality of major retail firms' TCF MI and how well they use this to make informed decisions and improve performance. Reports from these assessments have received positive FSA feedback.
  • Outcome testing:  We have undertaken independent assessments of the outcomes delivered to customers. For a range of clients, this has included reviewing sales cases, claims handling, complaints, financial promotions and customer communications.
  • TCF Planning:  We assisted a leading insurance group to define its plans to meet the FSA's 2008 deadlines. The FSA gave the Group Board positive feedback on the quality and completeness of the company's plans. Work with this client has also included helping back-office functions such as Finance understand their role in implementing TCF.
  • Leadership Engagement to Embed Fairness:  We delivered a series of high-impact Master-classes for Directors and Senior Managers to assist them to understand how TCF was fully in line with the Board's customer-focused ambition, to translate TCF requirements into day-to-day leadership behaviours, and to define action plans to embed fairness into strategy, operations and culture.
  • Business Strategy:  We have asssisted clients to develop business-driven responses to TCF linked to their overall customer strategy. We have developed a common-framework to help each business area understand its TCF obligations and how TCF affects its operations.
  • TCF Assurance Review:  We conduct independent assurance reviews of a client's TCF programme, covering its Life, GI and Asset Management businesses. This work reported to the Group Board and identified the positive approaches taken by its UK businesses and highlighted gaps in the company's ability to manage TCF.

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