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When you first heard of the treating customers fairly initiative what did you do? Shrug at yet another scheme which seemed to be little more than a statement of the obvious. Express annoyance at impudence of the implied suggestion that you might not be treating your customers fairly? Or remark that as you had clients and not customers it clearly did not apply to you?

There are certainly residual dangers in the TCF initiative because behind an apparently innocuous idea is a form of regulation that could be defined retrospectively to mean whatever the regulator needed it to mean in the future. How would the actions of Equitable Life have been judged if presented on the altar of TCF?

At one level as agents of the client, IFAs have always been the standard bearers of treating customers fairly and indeed they would not have had a business for long if they failed to do so. At another; moving from a rules-based regime to one of concepts offers the industry a much needed opportunity to regain its moral compass.

The international market collapse has its roots in the post "big bang" movement from a self-policed market to one of regulators and rules. This has changed management attitudes. In the past, directors would police their businesses conscious that condoning poor business standards would lead to condemnation and social unacceptably from their peers. This pistol and a glass of whisky approach was a huge and inexpensive force for good.

Now directors are too keen to police their businesses by what the compliance department will accept. Compliance, in turn, is trying to double guess a regulator that cannot regulate something until it has happened and so by definition is always behind the game. This abdication of responsibility has led to a director's conscience being reduced to box ticking and exposes policy- and shareholders to losses and ever increasing regulatory costs.

Treating customers fairly has the potential for directors to reclaim overall control of their businesses and with it their moral compass. This is hugely important. If we as an industry are going regain the trust of consumers we must start to run to our businesses not by playing to the referee's whistle but exclusively for the satisfaction to ourselves and our clients. We must also get in front of the regulators and start to reduce their role in the industry. After all if we are all treating cur customers fairly the FSA can concentrate on much needed prudential regulation.

As it has developed, TCF seems to have veered towards the regulator's desire for ever complex management information. While management information is important, it takes a profound concept and turns it back into a box-ticking process. This must be avoided.

Getting a definition of TCF from the regulator has proven difficult. When TCF was first proposed I visited Canary Wharf with a simple question: what would happen if a provider rejected a case were he was obliged under TCF to point the client to another source of cover? I never did get a practical answer.

So as responsible members of this industry what should we do with TCF? First, recognise how valuable this could be in rethinking our relationship with our clients. For years advisers have been retreating from giving clients a wide range of services into ever smaller areas of face-to-face advice. Clients are increasingly looking for simplicity and convenience from a single source. Advisers need to cover a far wider range of products and services than they currently offer.

Second, you need to get the TCF initiative away from the compliance department. Sure there is a compliance angle and no doubt loads of reporting but its benefit to your business is far more profound than just another rule change.

Remember there is only one person that can judge if you are treating your customers fairly and that is your customers. Here is an excellent excuse for you to see what your clients really think of you. Not all firms will be able to employ hoards of market researchers but there is a lot you can do by interviewing each other's clients about their experience with your colleagues and what products and services they would like you to offer. This will be time very well spent.

Finally, TCF offers to an opportunity to change the thinking of a whole industry. It is not good enough to ask is it compliant. It gives directors the vehicle to make TCF an individual responsibility. Not just for advisers but for all members of staff. So what is my definition of TCF? If you open your front door to a camera team from Watchdog and can explain your actions satisfactorily then you have TCF about right.

Garry Heath is chief executive for Inspiring Financial Planners