Expo: TCF - there are no excuses

It has also said that those that fail will find themselves under intensified scrutiny as the regulator steps up its game.

Nausicaa Delfas, head of TCF team at the FSA, said: “Firms should have all of the information they need on TCF. It is over to them now and it is time for them to deliver.”

However Michael Coogan, director-general of the Council of Mortgage Lenders called the FSA’s response to detailed questioning “annoying” in that the regulator was unable to give specific procedures for firms to follow.

Delfas said: “Many firms ask if they will be alright if they do one thing or another. But firms have to go back to first principles. There is no checklist. Firms have to be satisfied they are meeting the requirements and delivering the outcomes. They also have to be able to prove it.”

Coogan added: “It is all about drawing a picture to the FSA of what a firm is doing and providing evidence of what has been done.”

By March next year firms will have to demonstrate they have the right level of management information to demonstrate where they are in regard to meeting the desired outcomes on TCF, and by the end of the year they will actually have to prove they are treating customers fairly.

The step up from showing the FSA that processes and procedures are in place to ensure compliance with TCF and actually being able to evidence that those measures are working will be substantial according to Delfas. She warned firms not to take the step up for granted.