This page shows examples of good and bad practice case studies when promoting financial services and Financial Conduct Authority (FCA) expectations for promotions to be clear, fair and not misleading.
Financial promotions are how firms communicate financial services and products to consumers. These promotions are often published in many forms such as on social media (Facebook, Twitter, Instagram), websites, as well as other media formats. They can significantly influence a consumer’s decision when choosing a financial product or service, so, it is vital that financial promotions comply with our relevant rules.
The FCA recognise the need to provide information for firms to understand the financial promotions rules that apply to particular products and services. The FCA have included below short videos of the various products they regulate, and the common mistakes firms make while promoting their products. The videos illustrate FCA expectations and highlights the need for promotions to be clear, fair and not misleading regardless of the media used.
These examples provided are mock scenarios. They are not a comprehensive illustration of the rules and it is for you to ensure that the promotions that you communicate or approve comply with all relevant requirements.
Video: Case study 1 – Consumer Credit – Car Finance (Hire Purchase)
This video includes the common mistakes we see for a car finance hire purchase promotion, these include:
• mentioning weekly/monthly payment without a prominent representative example
• using an incentive statement without a prominent Representative APR
• failing to include prominently credit broker statement
Video: Case study 2 – Claims Management Companies: Financial Service Products
This video includes the common mistakes we see for a claims management promotion, these include:
• failing to identify as a Claims Management Company
• failing to prominently include information about consumer’s right to make a claim for themselves for free
• failing to include the name of the relevant ombudsman or compensation scheme
• using ‘No-Win-No Fee’ statement or similar statement without disclosing fee/termination fees where applicable
If you’re unsure whether your advert complies with the relevant rules, you may wish to seek independent legal advice.
You should also review The Perimeter Guidance Manual which sets out the legal definition of a financial promotion, and what would be considered merely a communication to reference the firm’s brand (image advertising).
For more information regarding FCA’s media-neutral stance, please refer to this Social Media Guidance.
Handbook rules for firms
The links below will take you directly to the financial promotion’s rules within the FCA Handbook that relate to these high-level product areas.
- Consumer credit: CONC – Consumer Credit; CONC – Debt
- Claims management: CMCOB
- Retail investments: COBS
- General insurance: ICOBS
- Mortgages: MCOB
- Banking: BCOBS
Related: Financial promotions quarterly data
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