Management Information MI is the data or statistics collected to measure performance, and drive TCF compliant change where needed.
Financial organisations need to be able to show how they are using MI to:
- measure progress in implementing the TCF principles
- take action to improve procedures and customer service where required
- monitor the outcome of required changes, that then demonstrate improved standards in the fair treatment of customers
MI is akin to regularly taking the pulse of the organisation to review and take action on areas of TCF concern, and embed best practise. A leadership review of MI at least twice per month is recommended.
Management Information MI relating to Treating Customer Fairly TCF is not just about consumer satisfaction. Just because a customer is satisfied does not mean they are actually being treated fairly; similarly just because they are unhappy does not mean they are being treated unfairly.
The MI needs to be adapted to suit the needs of your particular organisation to ensure you adhere to TCF principles. Not all organisations need to gather the same data. The data you need will depend on the size of your organisation, and the areas of the market you service.
The purpose of Management Information MI data is to help you measure performance against:
- your stated TCF objectives
- your internal service standards relevant to TCF
- FSB (www.fsb.co.za) standards aimed at protecting the interests of consumers
- the entire value chain (From provider to broker to customer)
- Determine which below areas are relevant in your business relating to TCF
- decide within each what you need to measure and assess the deliver on TCF principles
- start gathering the relevant data
- TCF shouldn’t require the collection of substantial additional MI – it may, however, require thinking differently and managing the data already available in new ways
- Create an MI Plan documenting
- what TCF MI you’re gathering, why and how
- how often the TCF MI (including summaries) are produced and circulated, and by whom
- who they are circulated to (this will need to include senior management)
- how issues raised by the reports will be prioritised and actioned
Area that have been identified as being potentially important:
- culture and values
- business strategy
- product design and governance (more relevant for larger firms and product providers)
- marketing, advertising and financial promotions
- after sales service
- handling of complaints
Where a risk is identified in the Management Information MI data related to TCF it is essential to evidence what action you have taken to investigate the cause, and what corrective steps you are taking as a result. Additionally – how are you sharing what you have learned with key stakeholders to ensure efficient knowledge management?