Financial Promotions
Any breach of the FSA’s financial promotions rules calls into question a firm’s commitment and ability to deliver the right consumer outcomes; in particular, the FSA may focus on the effectiveness of internal controls as well as the ‘training & competence’ aspect of publishing compliant promotions.
Huntswood has worked with a number of high profile retail
financial services firms on varying aspects of financial
promotions work, providing both consulting advice and interim
compliance support:
- We reviewed and redesigned the systems and controls
around communicating with customers for a global
insurance firm
- We reviewed the financial promotions approvals process for a
top three UK life and general insurer
- We were asked to intervene in a top ten life and general insurer which was undergoing enforcement action for non-compliant financial promotions
- We have provided outsourced financial promotions checking solutions to wealth managers, life and pension providers, utility companies, banks and financial advisor networks
With the increasing emphasis by the FSA on consumer outcomes, how a firm communicates with its customers assumes even greater importance.
Firms’ communications remain a key and visible indicator of fairness as well as public evidence that a firm has grasped both the FSA’s Conduct of Business Rules and ‘Principles’ associated with financial promotions.
The FSA remains active in its investigation of financial promotions; 22,500 advertisements were reviewed in 2008 and 13 firms have been fined a total of £1.5 million in the last three years.