How does TCF apply to the unregulated business of a firm?
While the TCF principle does not apply directly to unregulated business, if we discover behaviour related to a firm’s unregulated business which arouses our concerns, we may use this as an indicator of risks in the firm’s regulated business. However, the TCF principle goes to the heart of a firm’s culture. In our dialogue with firms on TCF we have said that it is difficult to see how they could successfully introduce a culture in one part of their business (the regulated part) without simultaneously expecting the same approach elsewhere (the unregulated part).
