What is a ‘promotion’?
The term promotion covers a wide range of marketing and advertising. It includes websites, sales brochures, adverts in a magazines or newspapers, direct mail flyers – basically, it is anything seen, heard or read by customers that’s designed to influence or encourage them to reach a purchasing decision.
You can’t rely on your marketing people to keep your credit promotions compliant
As far as the FCA and the Advertising Standards Agency are concerned, the buck stops with a company’s senior managers. You can’t rely on your creative agency to ensure you’re compliant. In fact, most marketing, web design, and advertising agencies have little or no knowledge of credit advertising legislation.
If in any doubt, you should engage a specialist lawyer to check materials before you print, publish or broadcast.
Make sure you cover the basics
When promoting finance, you should include your legal company name, and the following statements:
- Authorised and regulated by the Financial Conduct Authority
- Credit is subject to status
If you include a representative example, then you’ll also need to add your company’s registered address.
Rules are slightly different for broadcast advertising so always check requirements.
Representative APRs & Representative Examples
When describing finance products you must include either a representative APR or a representative example. There are specific rules on when and how this information must be displayed.
You can find out more by reading our Quick Guide to Advertising Regulations – call 08450120 6666 if you’d like a copy.
Using lenders’ logos
When you’re partnering with a ‘blue-chip’ lender, it’s understandable that you’d want to use their logo and make reference to them. After all, it’s likely to reassure customers that your finance products are underwritten by reputable lenders. But you need to remember that logos and company names are the intellectual property of the lender and you can’t use them without first obtaining written permission.
Finally, the ‘golden rule’ of all promotions…
Whenever you’re creating promotional materials or advertising you must ensure they’re clear, fair, accurate and not misleading. Use plain English that can be understood by an average member of the public, and don’t be tempted to make exaggerated claims about your company, products/services, or the finance options you offer.
This article is intended as a basic guide only, it’s not intended as formal advice. For more information please read the FCA’s CONC guide to advertising http://fshandbook.info/FS/html/handbook/CONC/3