FSA guidance on TCF gets curiouser and curiouser
MORTGAGE DISTRIBUTOR - 1ST AUGUST 2007
There will have been gasps of relief in the mortgage industry following the Financial Services Authority’s decision to publish guidance on treating customers fairly.
However, many will be scratching their heads and wondering if the FSA commissioned Lewis Carroll to write it - some of the language could have come straight out of Alice in Wonderland.
Firms have been advised to consider their product design, marketing and selling, and post-sale service and complaints handling. But against what benchmarks are they to be measured?
At least the FSA accepts that there are a wide variety of relationships between distributors and providers. Curiously, it concludes that one of the advantages of principles-based regulation is that “we are able to draft materials that reflect this”. It adds: “We recognise, however, that use of the terms ‘distributor’ and ‘provider’ in the DP may have caused some confusion.”
As the duchess in Alice in Wonderland said: “Be what you would seem to be – or if you’d like it put more simply – never imagine yourself not to be otherwise than what it might appear to others that what you were or might have been was not otherwise than what you had been would have appeared to them to be otherwise.” Quite.
Simon Burgess
Managing director
British Insurance
