I’m Kirk Ford and I’d like to take this opportunity to introduce myself and tell you a little about what I do and how I can help you.
I have worked in financial services for 12 years, including 6 years working for HSBC, giving me experience and a unique insight into the finance industry.
I also have extensive experience of working in a number of roles that have involved advising clients on their finances and this has enabled me to gain first-hand experience of having to adhere to T&C processes.
These roles included working for Gocompare.com as a Compliance Manager, and 18 months in a start-up firm where I was responsible for writing and administering the firm’s T&C Scheme to ensure that brokers were competent to undertake their role effectively.
My current role as a Compliance Consultant allows me the opportunity to work with different firms and advise them on their T&C processes. The most important thing I have learnt is that all firms are different in size, staffing and approach. My experience, flexibility and personable and friendly approach helps to ensure that I can help your business implement the best possible T&C plan for you.
One of my hobbies growing up was, and remains, boxing. I absolutely loved watching the big fights and I was intrigued by the level of skill involved. When I was younger, I always remember my uncle taking me and my brother to a boxing session. It was fair to say, one session was enough for me and I never returned. My mum always said “Kirk’s scared of his own shadow”. This would all change when I got a bit older and more regarding boxing will follow later.
Training & Competence
‘T&C’ - formally known as training and competence - is not a new idea. The General Insurance Standard’s Council launched their own rules and elements of these can still be seen today under the current FCA T&C rules.
The FCA’s training and competence regime support consumers by making sure that the financial services workforce is appropriately qualified and regulated.
Individuals must be assessed as competent by their firm, maintain competence through training and meet standards of behaviour.
Bearing the above in mind, I ask myself what is the aim of T&C? To me, the purpose of T&C is to drive up standards of advice and service within the financial services industry by ensuring your employees are competent to perform their role. Having competent employees will surely help to ensure customers are treated fairly.
How competent are your employees?
How competent are you and your employees and how do you know? These are probably the first two questions the FCA may ask you when they visit.
Conduct and Culture
The FCA has linked poor customer outcomes to employee competence and as a result there is increased attention on culture, values, ethics and behaviours to ensure that the focus remains on customer outcomes.
I would highly recommend that you consider what ‘good’looks like by considering Knowledge, Skills and Ethical Behaviours. These can be built into your KPI and Competence sets which will then help you to identify strengths, weaknesses, risks and gaps.
Culture drives behaviour. In my opinion, an employer who regards T&C and staff development as an additional expense or a tick box exercise is likely to be a higher risk. A firm that regards T&C and development of staff as a crucial component in enhancing employee performance is likely to be regarded as lower risk.
What are the benefits of a T&C Scheme?
There are clear benefits for firms and consumers when employees are competent in their role and the firm encourages a culture of improvement. Examples would include the following:
Firms benefit from:
- higher levels of efficiency, leading to lower operational costs
- fewer errors requiring correction, which will reduce operational costs
- higher levels of employee satisfaction, recruitment and retention where there is a development culture in the organisation
- lower levels of complaints, leading to lower redress and compensation costs
- lower risk ratings from the Regulator and less likelihood of regulatory disciplinary action
- better productivity; more effective succession planning
- higher levels of customer satisfaction through improved service standards
Consumers benefit from:
- higher levels of confidence in the firm
- better customer service – quicker responses and fewer mistakes
- higher standards of advice
Before I go into a firm to plan their T&C Scheme and look at competence, I always ask a few key questions:
- What do you want employees and agents to do that they cannot do now?
- What do you want to be able to demonstrate to the Regulator?
- What do you want customers to feel about your organisation that they do not feel now?
The ultimate focus of the Regulator is that General Insurance practitioners deal fairly with customers and give them a competent and efficient service.
The FCA is accountable for the conduct of all financial services firms in the UK. As such, the FCA’s main role within T&C is setting out the principles within which companies should operate, defining specific rules/guidelines for T&C and updating them when appropriate.
The FCA is not responsible for deciding how companies should implement T&C and the design and execution of individual schemes.
How difficult is it to write a T&C Scheme?
I believe experience is the key to producing an effective T&C Scheme. I have written numerous T&C Schemes for all types of firms, both small and large. It is imperative that you write a scheme that supports, develops and assists in excellent outcomes for customers.
Firms are required to establish appropriate procedures to meet the FCA requirements. While there is no formal requirement for these procedures to be in writing, it is considered good business practice for them to be documented in a T&C scheme.
A well-written scheme will outline the requirements in an unambiguous, clear and concise way and will promote consistency across the company.
Importantly, written procedures also allow for quality control. Auditors, assessors and the FCA will be able to compare what is documented in the scheme with what is actually happening.
As I have mentioned, every firm is different, so there is no ‘one Scheme fits all’.
Some things to consider include:
- Constructing the Scheme in the first place - who will have responsibilities within the Scheme?
- adequate spans of control: how many employees per supervisor is acceptable?
- record keeping
- KPIs and ensuring the Scheme is effective in assisting employees to achieve and maintain competence.
I believe that a good T&C scheme will focus on simplicity and clarity, with user-friendly processes and documentation – why complicate things! The word I tend to use that describes my approach to T&C is ‘proportionality’.
I have already mentioned my love for boxing. Three years ago I put my name forward to have a boxing fight. Having lived in a world of training and competence, I knew it was vital to learn the skills of boxing before I entered the ring. I wanted to make sure I was one step ahead of my opponent so I learnt different skills and techniques which involved both offence and defence. The point I’m making is, it doesn’t matter what your goals are, I truly believe a well thought out and documented plan will help to set you and your employees up for success!
A T&C Scheme will lead to higher levels of efficiency and lower the risk ratings from the Regulator. It also helps to instil a culture of development and competence in the firm.
For more information or just a chat, contact me at firstname.lastname@example.org.