Financial promotions are a vital part of competitive markets, engaging consumers and helping them make informed decisions.
The FCA is continually updating its rules for Financial Promotions (FinProms), and under the Consumer Duty, the bar for delivering good customer outcomes is higher than ever before.
Do your FinProms lead to good consumer outcomes? Have you validated that your FinProms processes are in line with the regulator’s expectations and best practice?
Check your FinProms are compliant with the FinProms Audit
Firms ask us to audit their FinProms, checking that they are compliant with sector specific FCA rules and guidance, and also the Consumer Duty. Firms also ask us to benchmark their FinProms against best practice in their sector, including social media, websites, emails, and brochures.
We map out the risks and potential consumer harms from your FinProms, providing assurance that the FinProms are appropriate, well-designed, and delivered over the right channels. We advise on areas of higher risk based on the potential for consumer misunderstanding and consumer detriment, and advise on whether customer communications are likely to be classified by the FCA as FinProms (or not). Where we encounter grey areas, we flag these and discuss how to best tackle them.
Our audit gives detailed guidance on areas of non-compliance, explaining the risks identified and suggested improvements to language, prominence of information, and design. We provide detailed advice on recommendations, and examples of best practice from other providers in your sector.
Where appropriate, we also conduct consumer testing on FinProms to deliver more insight into whether they are likely to deliver good customer outcomes.
Deign efficient compliance processes with the FinProms Governance Review
Firms ask us for support with their FinProms creation and review processes and governance. We provide commentary and guidance on best practice, identifying areas that should be strengthened in line with what the FCA expects of firms and industry best practice. We provide assurance on any areas of nuance, drawing on our experience and knowledge of what the regulator requires. We highlight any areas of potential risk within the process and provide suggestions to make the process more robust.
Upskill your team with the FinProms Masterclass
We offer bespoke in-person training classes for teams who are designing, writing and approving FinProms. We cover the regulatory expectations, the behavioural science frameworks, and the relationship between FinProm rules and the Consumer Duty. We explain the definition of a FinProm, how to ensure FinProms are fair, clear and not misleading, and how to design good social media FinProms. We tailor the examples and applications to the products you sell.
We asked Fairer Finance to deliver training on financial promotions for our marketing and product teams. Their insight into the Consumer Duty and its implications for financial promotions was particularly valuable. We would certainly partner with Fairer Finance again to deliver further training, and for further support on FinProms.
PAUL CAIRNEY, HEAD OF MARKETING, NEWCASTLE BUILDING SOCIETY