Regulation around financial promotions seems straightforward but the practical application of ‘fin prom’ rules can be more complex than you think.
Simply defined, a financial promotion is material that is issued by a firm as an ‘invitation or inducement to engage’ in the business of that firm. In other words, it covers anything that promotes your brand or your firm’s products, and any communication that invites or attempts to persuade customers to buy the products you market.
The financial promotions rules also include products promoted by ‘appointed representatives’ – an area of recent FCA scrutiny. Financial promotions aimed at intermediaries, such as brokers also fall under the regulator’s rules.
The regulator has the power to ban your promotions if they don’t stand up to its requirements. And apart from the reputational damage that can result, non compliance can also result in enforcement and a hefty fine.
How can Bovill help with your Financial promotions?
Many of our team have worked as in-house compliance officers and are used to reviewing and approving financial promotions. We also understand where the regulator is coming from, and can help you in a number of ways.
Conducting financial promotion reviews and developing policy
We can work with your marketing and business teams to review brochures, teasers and presentation materials and assess their compliance with the rules. We can also prepare bespoke policies so that regulatory requirements are being met from the initial product development and through all phases of the product lifecycle.
Assessing your website for financial promotions compliance
Your website is a key channel for potential investors to access information on your products and services. We can review content and disclaimers to make sure they are in line with the regulations and are presented in plain language with minimal use of jargon.
Understanding the impact of financial promotions rules on social media
Social media is being used more regularly with potential investors. We can review your policies, based on best practice, and review your online presence to identify any potential risks. Due to the continual evolving nature of social media it is essential that your policies are flexible enough to be applicable to all of the different formats now available.
Developing your financial promotions regime
As well as the specific elements of marketing, it is important that the structure and governance of your financial promotions regime complies with the spirit of the rules as well as the letter. We can perform independent reviews of your governance and policies, as well as your distribution strategy.
Get in touch with our team to find out more.