The FCA has revealed that TSB Bank plc has been fined £10.9m over their treatment of customers who faced financial difficulty. The regulator also identified that TSB did not have adequate systems and controls in place to ensure fair treatment and outcomes for these customers.

 

In response, TSB is taking significant steps to rectify the situation by setting aside £99.9 million to compensate more than 230,000 customers who have been impacted. These customers include those with mortgages, overdrafts, credit cards, and loans.

Perception vs reality

The regulatory review and fine for TSB highlight a critical question: how often do companies accept controls as effective without appropriate challenge and assurance?

TCC’s experts regularly see firms go through the initial process of implementing controls without consistent levels of minimum challenge and assurance testing. Commonly, we witness situations where a firm’s risk and control framework incorrectly indicate everything is low risk due to control (in)effectiveness. However, on closer inspection, there is evidence suggesting reasonable doubt in the control scoring and consequently the extent to which policies, procedures, processes, and oversight are affected.

The devil’s in the detail

Certainly, companies never aim to deliver subpar results. Yet, in substantial organisations like TSB, the vastness of their operations naturally presents challenges in spans of control and difficulties with consistency. The core issue often remains consistent, meticulous attention in risk assessment and control management while acknowledging the significant role ‘human nature’ plays in achieving a common standard.

Examples that can lead to poor outcomes include:

  • Control integrity and risk evaluation being intuitive, essentially communicating someone’s view rather than a prescribed underlying set of clear risk scoring methodology
  • Boards and committees wanting the ‘short version’ leading to insufficient time to challenge, which in turn results in an ‘over-dependence’ on MI at face value
  • Evidence of ‘group think’ arising from the loudest voice and conversely apathy of those who are happy with the ‘status quo’ – suggesting culture and the wider SMCR regime is not sufficient to promote and pursue the right outcomes
  • Lack of planning in Consumer Duty standards, leading to outdated policies and processes
  • Culture soundbite environments without links to process, which deliver the statement and equally damaging ‘computer says no’ attitudes. This can occur at all levels within an organisation
  • Lack of empowerment and/or empowerment without control including initial and ongoing training

Grasping the significance of the Consumer Duty and the related regulations is key to unlocking a firm’s enduring success and fortifying its long-term strategic vision – and that’s where entrusting independent, external expertise can prove invaluable.

TCC’s industry practitioners and ex-regulators work with businesses every day to review their systems and controls and provide specialised insight to provide longstanding success. Get in touch to find out how we can help your firm.

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