Delivering to FSA regulatory deadlines

Bupa had a challenge to delvier and embed Treating Customers Fairly (TCF) principles across its six business units. With a looming deadline the group was still seriously struggling to get traction with the regulatory change for the new Treating Customers Fairly rules (TCF).

Their challenges

Six companies within the Bupa group sell healthcare insurance products. At the point where our consultants were brought in the group had not significantly progressed what the six TCF outcomes would look like so naturally had not advanced how this would be delivered. As TCF had a deep impact this required a complex delivery across the businesses, different locations and different business functions.

Our approach

Working on behalf of the Operations Director our consultant immediately established a programme of work, the appropriate governance structure, controls and reporting. Then, arguably the most influential factor for the successful delivery, was to persuade the senior management teams from all six business units to collaborate as one unified working party. This delivery strategy enabled the businesses with certain more mature functions to support those that were weaker in those areas. Our consultant then established a programme delivery team assigning project managers to support businesses in implementing their changes.

Programme outputs

• Programme governance structure
• Programme controls and reporting
• Processes for managing risks, issues and changes
• Programme plan and schedule
• Detailed project plans
• Staff communications about TCF an the change journey
• Analysis of changes required to the businesses
• Product changes
• Sales process change
• Staff training
• Supervisory controls
• Operational process changes
• MI and senior management controls for ensuring ongoing TCF compliance
• Collecting evidence of TCF compliance for the FSA submission
• Deloitte resourced pre-submission ‘rehearsal’ audit
• FSA evidence submission

Outcome

The intervention turned around the status of the business change and enabled Bupa to successfully meet all TCF requirements, for all six businesses, within the mandated FSA timeline.