Financial Promotions and Adverts

  • Posted on: 12 June 2018
  • Written by: Iain Stephen

You must think carefully about promotions for deposits, investments, mortgages, insurance and consumer credit. Promotions for these products must be fair, clear and not misleading.

Be fair

Products and services are usually marketed to attract as many customers as possible. We often see that this leads to products being marketed in a way that's unfair, for example by:

  • Using misleading headlines

  • Making unfair comparisons

  • Displaying important information only in the small print, or

  • Not displaying the risks of a product or service prominently enough

Be clear:

Think about what people both want and need to know. We see many examples where firms don't provide enough or the right type of information. Be clear about the product or service so that the person buying it can make an informed decision. For example, if it is an investment, what will the money be invested in? Remember that:

  • People have different levels of understanding about financial products

  • People outside of your industry usually won't understand your industry's jargon or technical terms

Avoid misleading customers

Your firm will have more knowledge of the product or service than the person buying it. We believe firms should:

  • Ensure that promotions are balanced and not give too much prominence to the benefits associated with a product without also highlighting the relevant risks

  • Not ‘cherry pick’ data about a product or service

  • Not create unrealistic expectations

Examples of how unrealistic expectations can be created are:

  • Advertising savings that turn out to be smaller than those you'll actually get

  • Using headlines that imply attractive rewards, when in reality such rewards are only achievable in limited circumstances

How to be fair, clear and not misleading

In order to achieve this your company must put in place a number of systems and controls to make sure that:

  • People designing and approving promotions understand the rules

  • Promotions remain clear, fair and not misleading over time

  • You monitor promotions and keep adequate records

  • You review complaints and apply lessons learned to future promotions

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