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Financial promotions and digital media – generally

2 half-days with case study examples – this course can be adapted to different types of business


1: Introduction

Welcome and objectives

Promotions beyond the FCA rules – Codes of Advertising Practice, law, good taste



2. Did we issue a promotion? 

What is a financial 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 – communications to press and investment professionals

The effect of rule breaches – punishments in FSMA for breaching the rules


3: The Rulebooks


Finding the key rules for promotions


The FCA Principles relevant to promotions

What do the conduct of business rules apply to?


Clear, fair and not misleading in the conduct of business sourcebooks and the ASA Codes

The Consumer Duty – PRIN 2A

FCA and ASA approaches to clear, fair and not misleading

Risk disclosure

Rules for restricted and non-mass-market investments (where relevant)

Special COBS 22 rules on contracts for differences (where relevant)

Disclosure of any security for loans or specific mortgages and scarcity of availability of credit

Prominence & font-size rule

Rule against unfair comparisons

BSA/BBA Guidelines – bank accounts (where relevant)

Direct offer rules for savings accounts (where relevant)

Rules and guidance on specified expressions


Making promotions identifiable as such

Giving the name of the firm

Naming the regulator and compensation scheme

Past, simulated and future performance – only for investments


4. Mainstream issues in Digital media and promotions


Social media

Pay-per-click and other sponsored links


Unsolicited e-mail (where relevant)

Disclosing how to complain


5. Systems and controls


Risk Management and three lines of defence

Role of compliance

Approval of promotions for others



Get in touch

Contact Adam by e-mail, phone or post at:

E-Mail: or

Mobile: 07900 248150

The Attic, 117 Priory Road, London NW6 3NN.