Two half-days using case studies from the company
Introduction
Course objectives
The real world – Ordinary law, good taste, company procedures
ASA Codes of Advertising Practice
Defining Promotions
Statutory definition of a financial promotion
Is the firm responsible for the promotion? – retweeting, liking
Non promotional communications
Promotions of non-regulated activities
Image adverts and the impact on CONC’s application
Excluded communications and the Financial Promotions Order – communications to intermediaries and press
The FCA Principles and their application to exempt promotions
The FCA’s powers
Rule-making powers
FSMA Punishments including naming and shaming
The FCA CONC Handbook
Finding the rulebook and time-travel
Scope of application of CONC
Identifying the parts of the CONC that apply
Clear, fair and not misleading under CONC and CAP
Clear, fair & not misleading – its meaning in CONC and the ASA Code
Disclosure of security and limited availability of credit
Representative examples and APRs (when needed)
Comparisons and pricing claims
Competitions and ASA CAP 8
Disclosing regulated status
Need for promotions to be identifiable
Specifically digital media problems not already covered
FG 24/1 Social media and customer communications
Pay-per click & search engine optimisation
Website issues
Complaints disclosure on websites
Basic risk management
Sign-offs
Key management information
Identifying and prioritizing risks
Record keeping