What to watch out for to keep your financial promotions compliant
To help you ensure all your financial promotions are in line with the FCA advertising guidelines, we have detailed areas to watch out for that could mean financial promotions are not compliant. You should take legal advice if you are unsure of the requirements.
Subject to status not displayed:
Subject to status must be displayed where finance is advertised to customers. This avoids implying that credit is available regardless of the customer's financial circumstances or status. The FCA would be looking for this to be clearly displayed in banners or adverts so the customer is aware, at the start of the finance journey, that there are minimum requirements to be able to apply for finance.
Minimum spend not displayed:
The minimum spend must be clearly displayed at the start of the customer's finance journey to avoid them being led to believe finance is applicable on any amount of finance. Similar to the subject to status, this should be displayed with finance banners or adverts to the customer. This avoids disappointment to customers and it makes the sale of finance smoother.
Representative example is missing information:
By not displaying the full representative example to the customer, they are not being provided with all of the important information and charges that would apply to them, which could result in this being misleading. Refer to the V12 Retail Finance Credit Advertising Guide for guidance on exactly what is required for a compliant representative example.
Ensure important information is given prominence:
Important information should be displayed with prominence so the customer understands the details relating to their finance agreement. Prominent information can be displayed in a text size that is consistent with other text, and not smaller, so it brings attention to the customer. Prominence applies to all elements of a financial promotion, including the status disclosure, pre application warnings such as subject to status, minimum spend applies, details of the representative example, monthly repayment amounts, and representative APR.