In the FCA’s Business Plan for 2023/24, it prioritised reducing and preventing consumer harm, particularly in in financial promotions.

The FCA has now published its Guidance Consultation on Financial Promotions on social media.

Whilst firms may consider this to be aimed at ‘finfluencers’ and unauthorised firms, the consultation acts as a timely reminder that the financial promotion rules apply across all forms of social media.

And the FCA is concerned that the increasing speed with which financial promotions can reach consumers is leading to them being of poor quality or lacking in sufficient detail – both of which have potential for consequential consumer harm.

Four questions to ask yourselves:

1. Do your processes allow for appropriate control, e.g. sign off, oversight, shelf life of all activity and content?
2. Do your procedures ensure blogs, vlogs, Facebook, X, Instagram, TikTok, LinkedIn and many others meet the required risk warning and prominence requirements?
3. Do your procedures enable you to monitor your advisers’ social media activity to ensure non-compliant content is not published?
4. Do you have appropriate MI to monitor risks associated with such promotion mediums, including evidence of consumer understanding?

TCC is working with firms to analyse and manage these challenges.

Let’s talk… Contact us for an exploratory conversation about your own individual views and risks. Plus get an introduction to who we are and how we build ongoing relationships with our clients on trust and value.