As we reported in May 2007 , the TCF “implementation” deadline tested whether firms were implementing necessary changes in a substantial part of their business. Firms were expected to have allocated appropriate resources and responsibilities, developed plans and processes, and created capability to meet the TCF principle. We would expect a firm’s implementation plan to identify and tackle any gaps in their ability to ensure customers are treated fairly, including the designing and selling of PPI. We have set firms a deadline of December 2008 to complete their work on TCF and to demonstrate they are consistently treating their customers fairly in all aspects of their business, including.
