Firms must be able to demonstrate that they have taken reasonable steps to ensure that any non-real time qualifying credit promotion is clear, fair and not misleading. This is a key requirement under the Financial Conduct Authority (FCA) rules, designed to protect consumers from being misinformed or confused when considering regulated products.
Reasonable steps include carefully reviewing the wording, content and presentation of the promotion to ensure it accurately reflects the product features, costs and associated risks. Firms should also consider whether any claims or comparisons made could give the wrong impression about the affordability, flexibility, or benefits of the product.
It is important to document the steps taken to review and approve the promotion. This may include records of internal checks, approvals, and any advice sought from compliance or legal teams. Being able to evidence this demonstrates that the firm has acted diligently to meet its regulatory obligations and to avoid consumer detriment.
Regularly reviewing promotional materials, particularly when products change or new marketing campaigns are launched, is essential. By doing so, firms not only comply with FCA rules but also build consumer trust and confidence, ensuring that communications are always transparent, accurate, and aligned with the firm’s commitment to fair treatment.
