TCF Compliance for South African Insurance Brokers: A Practical Guide

# TCF Compliance for South African Insurance Brokers The Financial Sector Conduct Authority (FSCA) requires all FSP-licensed brokers to demonstrate adherence to the **Treating Customers Fairly (TCF)** framework. This is not optional — it is part of your market conduct obligations under the Financial Sector Regulation Act (FSRA). ## The 6 TCF Outcomes FSCA measures TCF compliance through six defined Outcomes: 1. **Outcome 1 — Culture:** Customers are confident they are dealing with firms where TCF is central to the culture. 2. **Outcome 2 — Products:** Products and services marketed are designed to meet the needs of identified customer groups. 3. **Outcome 3 — Clear information:** Customers are given clear information before, during, and after purchase. 4. **Outcome 4 — Suitable advice:** Where advice is given, it is suitable and takes account of customer circumstances. 5. **Outcome 5 — Performance:** Products perform as firms lead customers to expect. 6. **Outcome 6 — No post-sale barriers:** Customers do not face unreasonable post-sale barriers to complaints or claims. ## Practical documentation requirements To evidence TCF compliance, maintain records of: - All complaints received, categorised by FSCA TCF category - Resolution times and SLA compliance rates - NFO escalations and outcomes - Monthly compliance reports per FSCA Outcome ## The 5-day complaint SLA FSCA guidance requires brokers to acknowledge complaints within **five business days**. Breaching this SLA triggers a mandatory NFO referral obligation. Ensure your complaint tracking system enforces this deadline and sends early warnings at 50% and 80% elapsed. ## Monthly TCF reporting While not all FSPs are required to submit monthly TCF reports, having them prepared ensures you can demonstrate compliance on demand. Reports should cover: - Complaint volumes by TCF category - Resolution rates and average resolution time - SLA breach count - NFO referral rate ClaimPulse auto-generates these reports from your complaint and claim data.