ARTICLE
18 December 2008

FSA - Treating Customers Fairly

HF
Holman Fenwick Willan

Contributor

HFW's origins trace back to the early 19th century with the Holman family's maritime ventures in Topsham, England. They established key marine insurance and protection associations from 1832 to 1870. In 1883, Frank Holman began practicing law in London, founding what would become HFW.

The firm evolved through several partnerships and relocations, adopting the name Holman Fenwick & Willan in 1916. HFW expanded to meet clients' needs, diversifying into aerospace, commodities, construction, energy, insurance, and shipping. Today, it operates 21 offices across the Americas, Europe, the Middle East, and Asia Pacific, making it a leading global law firm.

HFW was among the first UK firms to internationalize, opening offices in Paris (1977) and Hong Kong (1978). Subsequent expansions included Singapore, Piraeus, Shanghai, Dubai, Melbourne, Brussels, Sydney, Geneva, Perth, Houston, Abu Dhabi, Monaco, the BVI, and Shenzhen. HFW also collaborates with Brazil’s top insurance and aviation law firm, CAR.

By the end of December 2008, the FSA expects all firms involved in retail business to be able to demonstrate, through the use of management information, that they consistently treat their customers fairly in compliance with Principle 6 of the FSA's Principles for Business.
United Kingdom Insurance

By the end of December 2008, the FSA expects all firms involved in retail business to be able to demonstrate, through the use of management information, that they consistently treat their customers fairly in compliance with Principle 6 of the FSA's Principles for Business.

The FSA has made it clear that firms meeting its TCF deadlines will receive less regulatory scrutiny of their TCF arrangements. However, failure to meet the FSA's deadlines will result in increased FSA intervention.

It is worth noting that some market commentators have criticised the regulator's use of internal management information as a point of reference in measuring good customer treatment noting that there is little or no evidence to link the two.

However, TCF continues as a high priority in the eyes of the regulator and they have made it clear that the increased financial pressure on firms resulting from the current adverse economic conditions is no excuse for firms to focus more on immediate problems and not on conduct of business requirements.

A reminder of what is required from December can be found at:
http://www.fsa.gov.uk/pubs/other/tcf_deadline.pdf

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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