Financial promotions
The following rules apply to the financial promotion (advertising) of life insurance polices.
The rules apply to all financial promotions with the following exceptions,
- Letters and other communications only directed towards one customer or potential customer. This removes normal letters between a life office/IFA and their customer from the Financial Promotion rules.
- Communications about a specific product directed towards a specific recipient. The rules are aimed at communications towards groups or several persons and not just advice given to one person about a product specifically for them.
- Personal quotations or illustrations.
- A promotion that only contains the following,
- The name of the firm,
- The name of the investment (policy),
- The contact point,
- The firms logo,
- A brief factual description of the firms activities, fess and products,
- The price of yields of investments and charges,
- Real time promotions. A real time promotion involves interactive dialogue such as a personal visit or telephone call.
Approval
All non real time financial promotions must be approved by an authorised person/firm. The person in the authorised firm must have sufficient expertise to check and authorise such promotions. Records need to be kept of the financial promotions that have been issued and their version reference. Any financial promotion which becomes out of date or is found to be incorrect or out of compliance must be withdrawn. These records need to record a copy of the promotion and who approved it.
Content
The non real time financial promotion must contain the following,
- The firms name and its address or alternative a contact point,
- It must be clear, fair and not misleading,
- Any comparisons must be to other investments designed to meet a similar need or purpose,
- Comparisons must be objective, relevant and provable,
- There must be no criticism of a competitor,
- Any statement of opinion must be honestly held and given with the consent of the persons concerned,
- There must be no force indication of the firms independence,
- The fact that the item is an advertisement must not be disguised or misrepresented,
- There must be no reference to approval by the FSA unless it has been obtained in writing from the FSA.
- A description of an investment must be fair and adequate, including a description of the nature of the investment or service, the commitment required from the customer and any risks involved,
- A financial promotion that gives details of past performance must contain a statement clearly in the main text, that past performance can not be seen as an indication of future performance,
- Past performance data must be relevant and cover a sufficient period to give a reasonable picture. The period of time the performance is given over should be mentioned.
- For a packaged product past performance figures must go back as least five years.
- Where the results of a specific fund do not go back a full five years, hypothetical details can be used but this must be made clear and they must be clear, fair and not misleading.
- If the product is from a group member then this must be stated.