2 half-days with case study examples – this course can be adapted to different types of business
1: Introduction
Rules, principles and ideas applicable to financial promotions
Promotions beyond the FCA rules – Codes of Advertising Practice, law, good taste
What is a promotion and the extent to which it matters?
Non-promotional communications and image adverts
Some exemptions from parts of the rulebook in the Financial Promotions Order
The FCA Principles
The effect of rule breaches – punishments in FSMA for breaching the rules
2: The Rulebook
What do the conduct of business rules apply to?
Clear, fair and not misleading in COBS 4 and the ASA Codes
Risk disclosure, prominence & font-size rule
Rule against unfair comparisons
Rules and guidance on specified expressions
Tax
Making promotions identifiable as such
Naming the firm, the regulator and the applicable compensation scheme
Past, simulated and future performance
3. Mainstream issues in Digital media and promotions
Social media
Pay-per-click and other sponsored links
Websites and disclosing how to complain
Unsolicited e-mail
4. Systems and controls
Sign-off procedures
Risk Management
The Compliance function
Approval of promotions for others (if relevant)