How does TCF apply to firms that have no contact with retail customers (especially wholesale firms)?
There are TCF responsibilities throughout the lifecycle of a product, even where there is no direct contact with the retail customer. For example, a firm that designs a product for retail customers must consider TCF while it is designing the product, even if the firm does not have any contact with the end-customer. Firms not covered by Principle 6 because they only deal with market counterparties will continue in the same way. However, Treating Customers Fairly is about more than ensuring that firms comply with Principle 6. Compliance with all our principles will contribute to achieving fairer outcomes for consumers – for example, Principle 2 requires a firm to conduct its business with due skill, care and diligence. The Treating customers fairly in wholesale markets speech given in April 2008 explains the types of firms to which our TCF work applies, providing examples of firms that would fall within and outside of the scope of this work.
