We recently looked at the new Markets in Financial Instruments Directive, exploring What MiFID II is and what you need to do to comply.
For Marketing teams, there are some essential areas of the new regulation to get to grips with.While many of the changes will be operational, others have a direct impact on your marketing and financial promotions. Last week we shared tips on how to make sure your financial promotions comply with MiFID II.
Here we look in more detail at one aspect of those promotions – presentations to clients and prospects.
How will MiFID II change their client communications?
A key aspect of the new regulations is that all communications to professional clients will be treated as financial promotions.
The impact of this is twofold:
- The content will need to comply with the FCA’s requirements on financial promotions
- Any communications to professional clients will now have be signed off by your Compliance team before they can be issued
This has implications for your presentation content, as well as your project management, approvals process and record-keeping policies.
What do the changes mean for your PowerPoint presentations?
Classifying presentations to clients as financial promotions makes them subject to a raft of new requirements.
- They will need to meet the regulator’s rules for financial promotions. Remind yourself what a financial promotion is and what rules apply.
- They will need to include risk warnings. And it’s not just about including the right one. It needs to be the right size (MiFID II says that risk wording needs to be in the same point size as the main text) and be sufficiently prominent. Read more about the rules on disclaimers and prominence.
- There are specific rules around performance data. The Directive says that performance data in charts needs to be displayed differently for retail and professional clients. You need to understand the differences and ensure that your charts are correct for your audience.
- Language needs to be suitable for your readers. (You can read more on this and best practice tips in our blog on writing content that Compliance can approve.)
What do you have to do?
All of this means that you’ll need to build in extra lead time for client communications – particularly in the short term while you get used to the new requirements.
This means not just allowing more time to produce compliant content, but including time for sign off by an authorised person.
It might also be worth doing an audit of current materials. If any existing promotions will still be used after 3 January, they will need Compliance approval and to meet the required standards.
And if some of your client communications are produced outside the Marketing team, you have work to do here too.
Particularly in professional services firms, comms materials are produced throughout the business. You need to audit all your communications and ensure they meet FCA standards. There are tips here on how to spot when your financial promotions are out of control – and what do to about it.
How can a slide library help?
An online slide library can be a huge help when it comes to PowerPoint presentation compliance.
A slide library can:
- Enable you to lock down approved data. This can be an effective way to ensure no unapproved or inaccurate content slips through the net.
- Make it easy to identify slides needing sign-off, by adding a ‘not approved’ watermark to new or edited ones. This can save your Compliance team significant time.
- Help with brand consistency by including correct versions of logos, brand-compliant fonts and approved imagery.
- Provide a searchable library of presentations, slides, videos and images – making it easy to find and share approved content.
- Remove out of date presentations and slides, or mark them ‘expired’, making spotting out of date content simple.
- Automate the creation of branded charts, tables and graphs – making your PowerPoints look more professional with less effort.
- Allow you to create brand-specific templates, with the right size risk wording.
- Group slides together to ensure the correct risk wording is used when performance/strategy slides are selected.
- Store two types of risk charts for professional and retail clients, enabling you to use the right one every time
- Set expiry dates to prevent non-compliant data or PowerPoints being used.
- Automatically update performance data – saving significant time compared to manually updating all performance slides.
Stepping up to meet stricter requirements
However you approach presentation compliance, the MiFID II requirements will mean stricter rules and enhanced requirements. This will mean extra work for your team – but with careful planning and the right tools, you can be prepared for the 3 January deadline.
For more tips on how you can ensure your firm’s PowerPoint presentations meet FCA standards, download our tip sheet, 7 tips for compliant PowerPoint presentations. It’s free and you can get a copy here.