This month, the FCA launched a new advertising campaign highlighting the imminent deadline for PPI claims.
The campaign encourages consumers to act before the window for PPI complaints closes in August.
At the same time, the regulator released the latest figures showing responses to its PPI campaigns to date.
PPI mis-selling has clearly been a huge issue for financial services firms. It remains the most-complained about issue for the FCA and the Financial Ombudsman Service. A BBC article written a year ago estimated that banks had paid out £30bn in compensation in response to PPI complaints.
Marketing lessons from PPImis-selling
For the banks’ balance sheets, PPI is an ongoing headache.
From a marketing point of view, though, the PPI horse has definitely bolted. Claims of mis-selling relate to financial promotions and customer communications dating back years.
Where PPI mis-selling is relevant, though, is in the lessons it can teach us about future conduct. How can we learn from mistakes made in the past to ensure our marketing and financial promotions don’t create a similar situation in future?
How to produce compliant financial promotions
PPI wasn’t all about published financial promotions, of course.
Much of the selling was done face-to-face – ‘real time financial promotions’, in FCA terminology. This meant that it didn’t fall under the strictest of FCA regulations governing marketing and sales activity.
But looking to the future, what can you do to ensure your published financial promotions and customer communications comply with the rules?
After all, compliance is essential whether you are producing hard copy brochures and documentation or digital marketing activity.
And although PPI is probably the best-known example of communications that failed to meet the grade, the issue of misleading communications is still as relevant as ever. The clarity of promotions has been in the spotlight again recently – there is no excuse for regulated Marketers failing to meet the FCA’s requirements, and no hiding place for those who do.
Minimise your risk of regulatory breaches in marketing
So – how can you make sure your promotions and communications live up to the regulator’s standards? Our 9 tips will help:
- Make sure you fully understand the FCA’s financial promotions rules. Refresh yourself by reading our blog, What is a financial promotion? – fundamentals for marketers
- One of the big issues with PPI was the fact that people were not made aware that they were being signed up for it, or what this meant. Your promotions need to meet the regulator’s requirements in terms of being fair, clear and not misleading. They also need to follow guidelines ensuring they are suitable for their target audience.
- Get a feel for what compliant content looks like. Our tips on writing content your Compliance colleagues can approve first-time will help you to understand what is acceptable – saving you time in editing and rework, and enabling you to speed your promotions to market while keeping them compliant.
- Don’t forget digital marketing. Your website and social media also fall under the FCA’s financial promotions rules. Make sure they’re compliant too.
- Get it right when it comes to small print. The Competition and Markets Authority recently launched a campaign about terms and conditions in the travel sector, which has lessons for all industries. Read more about making sure your small print is fair.
- Keep control of Marketing activity not done by your team. Whether promotions are produced elsewhere in the business, or by outside agencies, you need to retain responsibility for their compliance. Find out how to avoid the regulatory pitfalls when outsourcing marketing and how to get your financial promotions back under control.
- Even if you’re not regulated by the FCA, your marketing and advertising activity is still under scrutiny. The ASA and CAP set rules for and oversee all advertising in the UK, including websites – make sure you understand their role, their rules, and what they mean for your marketing.
- Keep up to speed with evolving regulation. The legislation you have to comply with is ever-changing – GDPR, for instance, has altered marketing practice since it came in last year. Make sure you keep pace with the rules governing your sector.
- Finally, financial promotions compliance isn’t all about the end result. Your production, review and approvals processes also need to be up to scratch to meet FCA requirements.
While this is non-negotiable, it can slow you down. Read tips on making your review and approvals process as efficient as it can be.
Many Marketing and Compliance teams are turning to approval workflow tools to make this process quicker and more robust – consider whether this might help you, and if this is a route to go down, find out how to make sure you choose the right marketing automation solution.
The Marketing Manager's Guide to Compliance
There are definitely lessons to be learned from PPI mis-selling. If the industry can improve in light of mistakes made in the past, that can only be a positive.
To help Marketing professionals keep pace with regulatory requirements and avoid their own compliance breaches, we have published a Marketing Manager’s Guide to Compliance. It covers the FCA’s rules; the roles of the Compliance and Marketing teams; the reasons for financial promotions regulation and the common pitfalls to look out for.
You can download a free copy of the Guide from our resource library.
Nothing in this document should be treated as an authoritative statement of the law. Action should not be taken as a result of this document alone. We make no warranty and accept no responsibility for consequences arising from relying on this document.