Treating Customers Fairly (TCF)
TCF is the FSCA’s outcomes-based standard for how FSPs should treat clients. This is a plain-English guide to the six TCF outcomes and what evidence a South African FSP needs to keep to show they’re being delivered.
What is Treating Customers Fairly?
Treating Customers Fairly (TCF) is the FSCA’s outcomes-based conduct framework. Rather than prescribing granular rules, TCF requires FSPs to demonstrate six client outcomes across the whole product and service lifecycle — from product design and target-market selection through advice, information, complaints and post-sale servicing.
What are the six TCF outcomes?
The six outcomes: (1) clients are confident that TCF is central to the FSP’s culture; (2) products and services marketed and sold in the retail market are designed to meet the needs of identified client groups; (3) clients are given clear information and kept appropriately informed before, during and after the point of sale; (4) advice is suitable and takes account of the client’s circumstances; (5) products perform as clients have been led to expect, and service is of an acceptable standard; (6) clients do not face unreasonable post-sale barriers to change products, switch providers, submit claims or make complaints.
How does TCF fit with the FAIS General Code of Conduct?
The General Code is the rule-based backbone (suitable advice, disclosure, record-keeping, complaints); TCF is the outcomes lens applied over it. In practice a well-run FAIS General Code compliance framework already delivers most of TCF — the additional TCF work is documenting the outcomes explicitly and monitoring for delivery, not adding entirely new controls.
How is TCF supervised?
The FSCA supervises TCF through both routine inspections and thematic reviews (specific outcomes assessed across a sector). During an inspection the FSCA will read TCF into the compliance monitoring plan, complaints data, product-approval processes, marketing material and advice files — there is no separate "TCF file", the evidence is embedded across the compliance framework.
How do I embed TCF in a small FSP?
For a small FSP: adopt a short written TCF policy stating the six outcomes and how the FSP delivers each; embed TCF questions in the compliance monitoring plan; log TCF-relevant themes from complaints; document the target-market thinking for each product offered; and review annually with the KI. Keep it in the same file as the compliance manual so an inspector sees it as one framework.
What evidence of TCF should we keep?
Evidence includes: a dated TCF policy and annual review; product-approval / target-market documentation; sample advice files that show suitability reasoning; the complaints register with outcome-oriented root-cause analysis; marketing and disclosure material with a fair-and-clear checklist; and staff training records covering TCF. The Annual Compliance Report includes a TCF outcomes attestation drawing on this evidence.