A quick guide to creating promotions that are clear, fair & not misleading
By Heather Carey
Whenever the topic of advertising compliance comes up, I’m often asked what the FCA’s central requirement, that promotions should be clear, fair and not misleading, actually means.
After all the words ‘clear, fair and not misleading’ are extremely subjective, and what’s crystal clear to one person, is clear as mud to another.
The FCA is not looking to trip companies up, they just want to ensure promotions give a balanced view of the finance being offering and don’t disguise or hide or omit any important statements. And all of that is perfectly reasonable and should be the goal of any business striving to ensure customers are always treated fairly.
What does ‘clear’ mean?
This is about making sure customers have all the information they want and need to know, so they can make an informed decision. People have different levels of understanding when it comes to finance, so try to keep it simple and use plain English wherever you can.
If there are any fees or key terms (such as minimum lending criteria) associated with the finance then make sure customers know.
You also have to make it clear who is promoting the finance, this means including your full legal name in the promotion (not just your trading style) and stating that you’re a broker not a lender (or appointed representative).
What does ‘fair’ mean?
Quite simply, don’t use misleading headlines or make any unfair comparisons, and don’t display the important information in the small print.
Put yourself in the shoes of your customers, if you were presented with one of your adverts would you feel like you were being treated with fairness?
What does ‘misleading’ mean?
You need to ensure your promotions are balanced; don’t cherry-pick which information to give people about the finance or create unrealistic expectations (such as implying finance is available to everyone).
A common misleading mistake is referring to a deferral period as an ‘interest free’ period – it’s not, interest is accruing.
Any testimonials or case studies you include, must be from real customers.
Also, if you’re promoting any cost-savings alongside the finance – such as reduced bills resulting from a new boiler – then the savings must be realistic and achievable by the average customer.
If you need any assistance with your next promotional campaign you can contact me on firstname.lastname@example.org