Real time financial promotions

Real time financial promotions

 Authorised firms need to make certain, as far as they reasonably can, that persons who make real time financial promotions on their behalf fit in with the following,

• The promotion is clear, fair and not misleading,
• Does not include any untrue claims,
• Makes the purpose of the promotion clear and identifies both himself and his firm at the start.
• If the meeting, visit was not pre-agreed, then makes certain that the customer/potential customer is happy for him to proceed with the promotion, and if not, then the promotion must stop.
• Provides the customer/potential customer with a contact point,
• The promotion should not be made on an unlisted telephone number or at an unsocial hour unless prior agreement has been obtained.

Direct offer financial promotions

Direct offer promotions need to contain sufficient material and information in order for the recipient to make an informed assessment of whether to proceed further with the investment or service.   The following information must be included.

• The standard statement detailing that the firm is authorised and regulated by the FSA,
• The recipient should be advised that if for any reason they think that the product may not be suitable they should either make contact for advice or seek advice from an independent IFA,
• The full name and address of the company offering the investment and if different the full name and address of the company communicating the investment,
• The name to whom payment should be made, this may differ depending on who can hold client money,
• Details of all charges and expenses involved,
• Details of any remuneration or commission paid to another party,
• Details if any of the information the recipient provides will be sent to another party.

A package product financial promotion must contain the details as required in the key feature rules.   These are rules that detail key details of the investment/policy that need to be conveyed to the potential customer in a short précis version.   If investments can fluctuate this must be pointed out. It must be clearly shown which benefits are fixed and which are variable.

The promotion must contain a summary of the taxation on the investment and the tax consequences of taking the investment out. Any assumed rates of tax must be clearly spelt out. When mentioning tax relief’s it must also be stated as to who they apply to, that they are the current position only and if they are reliant on the circumstances of the investor.

Where words ‘tax free’ is used it must be made clear that the set words apply to payout of benefits to the investor and does not apply to the fund earnings which will be subject to taxation.