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Ben Garside: What’s fair, clear and not misleading

Time 11:05 am, July 19, 2016

I’VE recently been on a course to fulfil both my own need for development and my company’s ambition to keep all employees competent in their roles, which is a usual occurrence at First Response.

I attended an external course on guidance of the Financial Conduct Authority’s financial promotion rules. While I believe we are already stringent when it comes to financial promotions, opinions vary as to what the advertising rules and guidance mean, so getting an external view is always a good thing. So what is clear, fair and not misleading?  Well, this is the most important thing that the authority has published in my opinion.

Here are some highlights from the FCA’s website:


Be fair: Products and services are usually marketed to attract as many customers as possible. We often see this leads to products being marketed unfairly.

Be clear: Think about what people both want and need to know. Be clear about the product or service so that the person buying it can make an informed decision.

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.

Anyone who has done any form of business or advertising course will be aware of the 5Ws. So let’s take a look at clear, fair and not misleading from that perspective.


Who – Is your target audience? Knowing the target for each communication (promotion) is key. It is this knowledge that will allow you to choose the headline messages you should promote.

What – Product are you selling? Lease purchase vs hire purchase, prime vs sub-prime.

This difference could bring in a whole batch of prescribed information.

Where – Are you distributing the promotion? The medium you place your advert in is also a significant consideration before producing your financial promotions. If your communication is going out as a post on Facebook, then the likelihood is that the people who could see your communication is varied, unlike a targeted direct mail campaign.

Why – Are you doing the promotion? You shouldn’t be doing a campaign just because figures are low one weekend. Your campaigns should always be about securing the right customer for the right products.

When – Are you doing the promotion and reviewing it? Simple.

These are my views and I advise businesses to read CONC 3 – the clear, fair and not misleading rule and general requirements – but as long as you know why and you can prove that you are being clear, fair and not misleading on each financial promotion, you will be in a great place towards giving good customer outcomes.

Who is Ben Garside? Ben is marketing manager for First Response Finance. Call him on 07817 518739 or email [email protected]

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