TCF
Treating Customers Fairly Framework
The FSCA's market conduct framework requiring financial institutions to demonstrably embed six fair customer treatment outcomes across product design, sales, service, and claims throughout the product lifecycle.
Sections
6
Duties
6
Questions
6
Assessment from
R 55 000
What it covers
Treating Customers Fairly (TCF) is the FSCA's overarching market conduct philosophy, first introduced in a 2014 discussion paper and now operationalised through specific conduct standards, the FAIS Code, and increasingly the COFI Bill which will eventually codify it into binding legislation. TCF requires financial institutions to embed six specific, measurable outcomes throughout the product lifecycle — from design through marketing, sales, after-sales service, and claims/complaints handling. The six TCF outcomes are: (1) customers can be confident they are dealing with firms where fair treatment is central to the corporate culture; (2) products and services are designed to meet the needs of identified customer groups and are targeted accordingly; (3) customers are given clear information and kept appropriately informed before, during, and after point of sale; (4) advice given is suitable and considers customer circumstances; (5) products perform as customers have been led to expect, and service is of an acceptable standard; and (6) customers do not face unreasonable post-sale barriers to change products, switch providers, submit a claim, or lodge a complaint. Unlike a single piece of legislation with discrete sections, TCF is a cross-cutting standard the FSCA applies in assessing conduct across all regulated activities — meaning evidence of TCF embedding is expected within an institution's product committees, sales incentive structures, complaints data, and claims ratios, not just in a standalone policy document. The FSCA conducts thematic reviews specifically targeting TCF outcomes and increasingly expects outcomes-based metrics (e.g. claims decline rates, complaint root cause analysis, product lapse rates) as evidence rather than policy statements alone.
Does this apply to you?
It applies if
- Your organisation is licensed or regulated by the FSCA in any capacity (FSP, insurer, retirement fund administrator, market infrastructure participant)
- Your organisation designs, markets, sells, or services any financial product or service to retail or commercial customers
- Your organisation handles customer complaints or insurance/benefit claims
Thresholds that change what's required
- TCF applies across the full spectrum of FSCA-regulated activity regardless of institution size — the FSCA expects proportionate but genuine implementation even from smaller FSPs
- Thematic FSCA reviews of TCF outcomes have particularly targeted credit life insurance, funeral policies, and retirement annuity products given historically poor customer outcomes in these areas
Exemptions
- TCF as a framework has no formal statutory exemptions since it is presently a supervisory expectation rather than standalone binding legislation, though once COFI is enacted, specific exemptions may be defined
What non-compliance costs
Maximum fine
R 10 000 000
Imprisonment
TCF itself does not prescribe imprisonment; underlying conduct failures may trigger penalties under the specific sector legislation (FAIS Act, Insurance Act) under which the conduct occurred
Civil exposure
Poor TCF outcomes frequently surface as upheld complaints before the FAIS Ombud, Insurance Ombudsman, or Pension Funds Adjudicator, with associated compensation orders against the institution
Reputational
FSCA thematic review findings on TCF are increasingly published and discussed in financial media; persistent poor TCF outcomes (high complaint volumes, high claims decline rates) damage broker and distribution partner confidence in placing business with the institution
What the assessment covers
The assessment works through 6 questions across 6 duties, scored out of 72. Each answer generates the specific actions needed to close or prove that duty — and a “yes” only counts once its evidence is in, which is what makes the score defensible rather than self-declared.
The questions themselves are part of the assessment.
Find out where you stand on TCF
Run the assessment, get your score, and get the exact list of what to fix — with the evidence trail an auditor will ask for.