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A different kind of Treating Customers Fairly course

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We built a different kind of TCF course because the recurring weakness we kept seeing was not the absence of policies or training. It was the gap between understanding the six Treating Customers Fairly (TCF) outcomes in theory and recognising how everyday decisions, records and behaviours contribute to them in practice.

Under COFI, “paper TCF” – policies, governance frameworks and training records that look good on paper – is becoming much harder to defend on its own. It is no longer enough to point to policies, frameworks and training completions. Organisations also need to demonstrate, with evidence, how fair customer outcomes are understood, supported and applied across everyday business practice.

Frameworks don’t treat customers fairly. People do. Evidence helps prove it.

James George, Compliance Manager at Compli-Serve, has spent years working with financial institutions across South Africa. On the surface, many of those environments looked well structured. The policies were there. The frameworks were documented. The training records were up to date.

Yet when you move from documentation into day-to-day work, a different picture appears. Employees could repeat the six TCF outcomes and point to the right documents, but still struggled to recognise where customer fairness was actually on the line in their own work. Just as importantly, many did not fully understand how their everyday decisions, records and actions contributed to the evidence their organisation would later rely on to demonstrate those outcomes.

This recurring gap between documented TCF and practical awareness is exactly what this course is designed to close.

COFI formalises the proof problem. It is no longer enough for an organisation to point to policies, frameworks and training completions. The harder question is whether fair customer outcomes are understood, embedded, acted on and evidenced in the way the business operates every day.

That is the question this course is built around: Do our employees understand how their everyday decisions, and the records they create, contribute to fair customer outcomes and to the evidence our organisation relies on to demonstrate them?

The insight: recognition is only the beginning

When we looked more closely at the gap, the pattern became clear.

Most TCF training focuses on explaining the framework. Employees are taken through the six outcomes, regulatory expectations and the organisation’s own policies, usually in chapter or module form.

But the moments that shape customer outcomes do not arrive neatly labelled as “Outcome 3” or “Outcome 5”. They appear as ordinary work:

  • a conversation where disclosure or expectation-setting is rushed;
  • an administrative task where a record is incomplete or ambiguous;
  • a handover where key context, commitments or risk indicators are lost;
  • a complaint or claim where process is followed but fairness is not consciously weighed;
  • a delay or error where the customer is left without explanation.

Employees do not need another round of information about TCF in the abstract. They need help recognising these ordinary moments as TCF moments, understanding which customer outcomes are affected, and seeing how their decisions, records and actions quietly support or weaken those outcomes.

That includes the administrative and record-keeping side of TCF. Fair treatment is shaped not only in advice or customer-facing conversations. It is also influenced by the accuracy of records, the quality of handovers, the handling of complaints and claims, the way delays are managed, and whether decisions and escalations can be explained later through a clear audit trail.

Recognition is only the first step. The next is understanding how everyday work creates the operational evidence organisations rely on to demonstrate fair customer outcomes, support oversight and intervene when something is going wrong.

Connecting the 6 TCF outcomes to everyday work and evidence

That practical awareness gap is why we designed this TCF awareness course around scenarios instead of chapters.

The six outcomes are still there. COFI expectations are respected. What changes is how employees encounter them. Rather than moving through theoretical explanations, learners move through realistic situations drawn from everyday work.

The course uses scenarios that sit inside ordinary operational contexts:

  • conversations and disclosures where suitability and fairness are at stake;
  • administration and record-keeping where accuracy and completeness affect what can be done later;
  • handovers between teams where context, timelines and commitments can be lost or protected;
  • complaints and claims where listening, documentation and escalation influence whether customers feel fairly treated;
  • escalations and delays where transparency and explanation are central to fair outcomes.

In every scenario, the question is anchored in the customer’s experience:

What happens to this customer’s outcome based on what you do next?

But the scenarios go further than asking learners to choose the fairest response. They help employees connect each of the six TCF outcomes to the everyday work, records and evidence created through ordinary business activity: what was explained, what was recorded, what was agreed, what was escalated, what action was taken and whether the organisation could later demonstrate appropriate oversight and intervention.

That design makes practical awareness the core skill being exercised. Employees are not only recalling definitions. They are practising how to recognise when fairness is on the line, understand which customer outcome is affected, and appreciate how their everyday work contributes to the evidence their organisation may later rely on.

How this Treating Customers Fairly awareness course supports COFI programmes

Compliance Online works in the employee-facing layer of compliance. Our focus is simple: Did the right employees receive the right compliance awareness, and can the organisation show what happened?

This TCF awareness course is designed to form part of broader TCF and COFI work as the scenario-based awareness component. Its job is to:

  • translate each of the six TCF outcomes into everyday situations employees can recognise;
  • help employees understand how everyday decisions and records contribute to fair customer outcomes;
  • strengthen the awareness layer that supports the organisation’s existing TCF structures;
  • generate awareness records and reports that demonstrate the organisation’s investment in employee understanding.

The course can be delivered through different Compliance Online routes, depending on how the organisation wants to manage evidence and reporting:

  • ELLO – structured e-learning where Compliance Online manages enrolment, reminders, learner support, tracking and reporting.
  • SCORM – content supplied for the organisation’s LMS, with internal teams managing rollout, completion records and reporting.

If the organisation also wants help evidencing employee awareness and acknowledgement of its existing policies, Policy Passport is a separate tool it should consider investigating. Policy Passport can support policy acknowledgement records and governance evidence, alongside this TCF awareness course.

The practical question for risk owners

For risk owners, the practical question this course is built to surface is:

Would our employees recognise a TCF moment if they were in one, and can we show what we have done to support that recognition?

If the honest answer today is “not reliably”, this scenario-based TCF awareness course is designed to help move that answer in the right direction. It helps employees recognise where customer outcomes are shaped, understand how their everyday work contributes to each of the six TCF outcomes, and gives the organisation a record of the awareness work it has done to support fair customer outcomes under TCF and COFI.

Under COFI, paper TCF is no longer enough. Firms will need to show that fair customer outcomes are understood, embedded, acted on and evidenced across everyday business practice.

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