When advertising mortgage services, firms must ensure that any financial promotion complies with the Financial Conduct Authority (FCA) requirements and is clear, fair and not misleading. One area that is sometimes overlooked is the disclosure of any fees that may be charged for mortgage advice or arranging a mortgage.
Where a firm may charge a fee in connection with mortgage business, this must be clearly disclosed within the financial promotion. The FCA rules require firms to include either:
- The actual fee payable, if the amount is known; or
- A representative fee, based on the type of business expected to arise from the promotion.
This requirement helps ensure transparency for consumers at the earliest stage of the customer journey. By providing a clear indication of any potential costs, customers are able to make a more informed decision about whether to engage with the firm’s services.
Firms should also ensure that the wording used in the promotion is accurate and reflects the firm’s charging structure. Where a representative fee is used, it should reasonably reflect the level of fees typically charged for the business generated by that promotion. It is also good practice to regularly review financial promotions, particularly when fee structures change, to ensure that all information remains accurate and compliant.
