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Brilliance

Trusted by 250+ financial services companies

Fair customer outcomes depend on
how the business behaves

Market Conduct is how a financial institution behaves in matters affecting customers. Fair customer outcomes do not happen by accident or as a by-product of good intentions – they are shaped by everyday decisions and actions.

COMMON CHALLENGES

Where managing Market Conduct gets difficult

Financial services leaders commonly describe challenges like these as they strive to get their organisations to deliver fair customer outcomes:

“Evidence-gathering is a pain”

“Not everyone knows what good evidence looks like, and our evidence sits in different systems and teams. Pulling it together takes time we don’t have.”  Want help, speak to Brilliance.

“We don’t know if we’re improving”

“We have reports and dashboards, but they don’t tell us whether customer outcomes are actually improving. Activity is visible — fairness isn’t.” Want help, speak to Brilliance.

“Third‑party risk is hard to manage”

“We’re accountable for brokers, UMAs and outsourced providers, but oversight and evidence vary widely.  It’s hard to get a clear view of how partners behave without policing them.” Brilliance can help.

“We aren’t getting traction”

“Everyone agrees Market Conduct is important and that fair customer outcomes must be delivered, but despite the effort, we still aren’t making any real progress.” Brilliance can help.

“Leaders are already under pressure”

“We make decisions under pressure without always seeing the impact on TCF outcomes. Commercial and operational demands often compete with fairness considerations.”  Brilliance can help.

“Complaint systems don’t cater for FSCA”

“Our systems don’t support the accurate complaint classification, product details and TCF outcome mapping required for FSCA reporting — especially for complaints handled by partners.” Brilliance can help.

Sound familiar?

Brilliance has already designed and implemented solutions to challenges like these for many financial services firms.
Those solutions are now available to you.

Trustiance

Create accountability, capture evidence and track improvement across the Market Conduct practices that influence fair customer outcomes.

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Outcomi

Consolidate conduct indicators, risk signals and operational metrics to monitor fair customer outcomes and flag areas below threshold.

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Resolven

Automatically classify complaints by TCF outcome, easily produce FSCA-aligned reports, identify root causes and track corrective action.

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Partna

Strengthen oversight of the third parties that affect customer outcomes, with structured assessments, evidence and accountability.

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COFIcheck

Identify readiness gaps, prioritise improvement and give leaders a clear, Board-ready view of where attention is needed.

Brilliance SaaS replaces multiple spreadsheets with a structured, reliable way to manage Market Conduct.

Leaders gain greater confidence and a more actionable view across the business.

SPEAK TO US

Specialist Market Conduct Consulting

Brilliance helps financial services firms turn Market Conduct and TCF principles, FSCA expectations, and COFI priorities into practical changes in behaviour, governance, and daily operations.

Every engagement draws on more than 30 years’ financial services experience and specialist expertise in delivering and measuring fair customer outcomes.

Our consulting support includes:

Market Conduct and TCF implementation, including COFI readiness

Conduct evidence, MI and improvement frameworks

Leadership, conduct culture and governance alignment

Board, executive and management workshops and training

Embedding TCF outcomes into business practices

Third-party conduct oversight

Complaints management optimisation

SPEAK TO US

Proven Market Conduct experience at scale

Why financial services firms choose Brilliance

Brilliance approaches Market Conduct as a business management challenge. We understand commercial and operational pressures and help firms embed fair outcomes into decisions, culture and operations while accounting for compliance and conduct risk.

Our work is grounded in TCF, COFI, Conduct Standards, FSCA expectations, complaints management and third-party oversight. Our software license fees are in Rand – not subject to exchange rate vagaries.

Consulting interventions are designed around each client’s priorities. Our SaaS products are configured for you, where requested can be custom modified to suit specific client needs.

Relevant Brilliance solutions incorporate guided practices, evidence recommendations, conduct indicators, automatic TCF classification and reporting structures.

Brilliance structures evidence, indicators and reporting so leaders can see where attention is needed, track action and demonstrate progress in fair customer outcomes.

With more than 30 years’ experience in financial services, Brilliance currently serves insurers, banks, intermediaries, UMAs, investment firms, employee benefits firms and retirement fund administrators.

Brilliance considers the people, behaviour, decisions, culture, governance and operational practices that shape fair customer outcomes across the business.

Questions about Market Conduct and TCF

Get clear guidance on Market Conduct, Treating Customers Fairly (TCF), conduct risk, COFI, complaints management and third-party oversight to help your firm deliver fair customer outcomes.

In South Africa, Market Conduct is how a financial institution behaves across its functional areas and third-party arrangements in matters affecting financial customers or financial markets. A key requirement is that the firm govern and manage this behaviour to deliver the fair customer outcomes, as set out in the FSCA’s Treating Customers Fairly (TCF) framework. Firms must therefore also mitigate the risk that their behaviour fails to deliver fair customer outcomes, as part of conduct risk management.

Evidence should show how the firm manages, monitors and improves conduct and TCF outcome delivery. Examples include:

  • Board minutes, decision and action records;
  • product and target-market reviews;
  • product and service performance analyses;
  • disclosure, advice and quality-assurance results;
  • complaint volumes, resolution times and recurrence rates;
  • claims, cancellations and root-cause trends;
  • third-party oversight and remediation reports.

Evidence documents should be current and granular enough to identify poor outcomes, causes and affected groups, and show that corrective action is taken, monitored and improves outcomes.

Measuring improvement in Market Conduct and customer outcomes involves five steps:

  1. Identify the conduct needed to deliver each TCF outcome.
  2. Select metrics and indicators that reveal changes in conduct and in outcomes.
  3. Turn results into meaningful management information for decision-makers by stating the TCF outcome and aspect measured, and comparing trends across relevant products and customer groups with baselines and thresholds.
  4. Investigate exceptions and root causes and take corrective action.
  5. Measure again.

Sustained positive change in conduct measures and customer outcomes demonstrates improvement.

What is the Conduct of Financial Institutions (COFI) Bill, and what does it mean for Market Conduct and fair customer outcomes in South Africa?
The Conduct of Financial Institutions (COFI) Bill is proposed South African legislation that will create a single, comprehensive and outcomes-focused framework for regulating the Market Conduct of financial institutions.

Once enacted, it will consolidate fragmented conduct requirements, place fair customer treatment at the centre of the legal framework, and support fair, transparent and efficient financial markets and trust in the financial sector.

To meet COFI’s requirements relating to fair customer outcomes, firms will need governance arrangements that embed fair treatment across the business and enable them to monitor and improve customer outcomes and demonstrate to the FSCA, with reliable evidence, that fair outcomes are being delivered.