Treating Customers Fairly (TCF)

Definition

Treating Customers Fairly (TCF) is an outcomes-based regulatory framework requiring financial services firms to show that fair treatment of customers is embedded in their culture and operations. It originated with the UK's Financial Services Authority and was adopted in South Africa by the Financial Services Board in 2011; it remains the backbone of the FSCA's market conduct supervision and is reflected in the FAIS General Code of Conduct and the Policyholder Protection Rules. TCF sets six outcomes: customers are confident the firm's culture is fair; products are designed for identified customer groups; customers receive clear information before, during and after the sale; advice is suitable; products perform as the firm led customers to expect; and customers face no unreasonable post-sale barriers to changing product, switching provider, claiming or complaining. The outcomes apply to brokers as much as to insurers.

What you need to know

In South Africa, every FSP is expected to be able to explain how it delivers each outcome and to produce evidence, from product selection to complaints handling; the FSCA's conduct standards and the planned Conduct of Financial Institutions framework build on the same six outcomes. NAMFISA, NBFIRA, Kenya's IRA and Nigeria's NAICOM have adopted similar market conduct principles with local variations. In the UK, TCF was superseded by the Consumer Duty in 2023, which demands harder evidence of outcomes; EU brokers work under IDD, which pursues comparable goals through documented processes rather than outcome monitoring.

For a brokerage on WhatsApp, three outcomes are directly in play. Outcome 3, clear information, requires messages in plain language, in the client's language where possible, with no ambiguous promises on cover or price. Outcome 5, products and service performing as expected, means questions, endorsement requests and claims received on WhatsApp must be handled within measurable times. Outcome 6, no unreasonable barriers, means a client who writes "I want to cancel" or "I want to complain" must get a reply and a procedure, not silence because the message sat on a representative's personal phone.

ORIS supports that evidence: a shared inbox with per-customer history, AI classification of incoming messages so that complaints and cancellations surface, visible response times, and CSV export for TCF reporting. See the POPIA and WhatsApp guide for the consent side, and the compliance hub for the wider framework.

Concrete example

During a routine FSCA visit, a Sandton brokerage is asked how it delivers TCF outcome 6. It produces an export of six months of WhatsApp conversations classified as cancellation or complaint, each with the date received, time to first reply and the procedure sent to the client. Before the shared inbox, those conversations were spread across five personal phones and could not have been assembled.