The final deadlines for implementation of TCF come into force this year. David Burrows looks at the current state of play and the practical implications for adviser businesses...
The FSA has made it very clear from outset that TCF is the responsibility of an adviser firm's senior management. It is not something that can simply be delegated to the compliance department. When conducting an on-site visit or one of their pre-arranged telephone conversations, (which seem on average to be lasting about two hours) the FSA will always demand to speak to senior management and will want to gauge how that management has embraced and implemented TCF principles. The bottom line is that a TCF culture has to come from the senior management down. Clear and effective communicati...
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