What do we need from you and why?

To meet the FCA’s expectations under the Duty there are circumstances where TSB will need to consider actions by other businesses, including:

Where TSB outsources activities to third parties
Under the products and services outcome and the price and value outcome, TSB needs to consider the wider distribution chain for its
products and services.

You have been identified as a distributor, meaning you distribute products manufactured by TSB. We are both required to share information to comply with the Duty, including information on target market, distribution strategy and value.

Although our Terms of Business already state that you will comply with all relevant law and regulations, which includes the Duty, we have set out some specific requirements under the headings below which we expect of you as a distributor of our products. Accordingly, for any new cases submitted to us by you after 31 July 2023, we will accept these on the understanding that you comply with the below, unless you specifically tell us otherwise in writing.

Should you become aware that you will be unable to implement any relevant element of the Duty before the 31 July 2023, please let us know as soon as possible. Likewise, should you, at any point, have any concerns with TSB’s compliance with the Duty, please inform us immediately. Please note that we may also ask for specific information from you regarding ongoing compliance with the Duty in our regular reviews with you.

You must let us know as soon as possible, and provide information on any action you are taking to mitigate or prevent further harm, if any of the following apply:
- You identify any issues in your reviews of distribution arrangements for a product or service.
- You identify any issues in respect of your treatment of customers with characteristics of vulnerability and ensure that their needs are taken into account throughout the advice and sales process.
- You identify any sales which have taken place outside the target market.
- You identify that a product no longer provides fair value.
- You identify that any charges (e.g. administration fees) you apply for distribution of your products no longer provide fair value.
We expect you to monitor and, where necessary, adapt your communications to our customers to ensure they are compliant with the Consumer Duty.

If you are aware of any issues with your customer communications which indicate they are not adapted to ensure they meet the needs of customers with characteristics of vulnerability, you must let us know as soon as possible and include information on what action you are taking to address this.
We expect you to ensure the customer support you provide meets customer needs, including those of customers with characteristics of vulnerability, regardless of channel used and before, during and after the sale of any product or service. Should you become aware of any instances where this has not been the case, you must tell us as soon as possible and include information on what action you are taking.