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Financial Promotions

2 Part Course  |  How to create Financial Promotions that comply fully with FCA rules and guidance

Financial Promotions Training Course

A one-day course presented in two half-day live webinars

Video Overview

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  • As a result of the largely harsh and perhaps unjustified LC& F mini-bond scandal fall out, Financial Promotions have been receiving closer attention recently. We have been keeping up to date with the regulatory responses and discuss the likely follow-up action
  • Crypto Assets and a proposed Regulatory Gateway are hot topics at the moment. We will include full coverage of these latest developments together with any other fresh imperatives or initiatives
  • We have been delivering this training for many years and we have been fortunate enough to train different sized organisations from different sectors of the financial community. As such we are certain we understand the underlying principles fully for regulated firms of all types.
  • We are completely up-to-date with FCA current thinking.
  • We are aware that recent FCA work has combined complaints handling with financial promotions with an expectation – not always met - that a root cause analysis should result in joined-up thinking and processes in these two critical areas.
  • Given our experience delivering this topic, we are well aware that the approach to promotions has matured over the years and we have adapted the course content to align with changing regulatory expectations and requirements.
  • We realise that FCA guidance on web-based promotions is now stale and was not terribly helpful at the time. Fortunately, we have been able to discuss this in-depth with many regulated firms and we believe we can add value by sharing the collective views on dealing with the regulatory gaps.
  • We do not use academics to deliver this workshop. We prefer hands-on, highly experienced practitioners who reached top management levels during their careers and have real experience in managing financial promotions risks.
  • The training is aimed at the practitioner and uses a commercial approach, where applicable. We emphasize the critical need to ensure promotions are fully compliant – that must always be the case - but we remind delegates that promotions must still be appealing enough for the front line to sell the underlying products on our behalf.
  • We use real-life examples and interesting case studies that illustrate the key points.
  • Feedback received from previous delegates has always been excellent.

  • Keep up to date with the latest news and thinking around this topic
  • Explain why financial promotions matter and why there is so much focus on this area
  • Understand the rules and be able to follow both the letter and the spirit of FCA guidelines
  • Create powerful promotions that are capable of selling products appropriately
  • Understand the approval process and the need for clear internal instructions, guidelines and processes
  • Recognise the significance and importance of the brand or image advertising and how and when this should be used in preference
  • Consider some topical and selective practice guidance publications (Thematic Reviews) and their impact on FP’s
  • Be aware of the impact of the Advertising Standards Authority on FP’s
  • Become familiar with the “rules” of financial promotions and exceptions
  • Consider the rules from your organisation’s perspective, COBS 4 & CONC 3 Know the difference between Real and Non-Real Time promotions and what this distinction means in practice
  • Understand the responsibilities of intermediaries, brokers and other third parties
  • How to approve a Financial Promotion from start to finish
  • Have in place an effective review process
  • Expand the understanding of record keeping including time periods, recording communications and FP records requirements
  • Learn about financial promotions using new media – probably the key marketing media for most firms
  • Gain insight into prominence and financial promotions looking at the thematic review
  • Consider numerous examples and case studies to understand what good and bad looks like

Part One

Financial Promotions – Latest News

  • Regulatory Gateway- Consultation
  • Crypto Assets Promotions Consultation
  • Recent Fines
  • Latest complaint data
  • Dear CEO letter following LCF scandal
  • Impact of MIFID II - Overview

What is a Financial Promotion?

  • Why do they matter? The meaning of “clear, fair and not misleading”
  • The meaning of “in the ordinary course of business”
  • Regulated activities
  • The vital need to distinguish between regulated and unregulated products
  • What rules apply – Conc 3, COBS 4 and/or MCOB3A
  • Media Types – no boundaries – any can be used
  • Types of financial promotion
  • Key issues to understand
  • Exercise: Consider some example promotions to determine whether they meet the rules

What is the drive behind regulation?

  • FCA role, responsibility and general approach to FPs
  • Financial Services & Markets Act 2000, s.21 – Application and Scope
  • The Financial Promotions Order 2005, PERG 8
  • The FCA’s Statutory Objectives
  • Principles-Based Regulation versus intrusive regulation
  • Treating Customers Fairly – extended by default by MIFID II
  • Principles for Business – general FCA requirements of a regulated firm
  • Clear, fair & not misleading in more depth
  • Targeting the right clients
  • Processes for excluding unsuitable applicants
  • Real-time promotions
  • Non-real time promotions
  • Exercise: Consider a proposal from marketing for a promotion. Is it a financial promotion? What changes are needed to either meet the mandatory requirements if it is or to avoid the classification completely

The General “Rules”

  • How the FCA regulates
  • Who is regulated and why?
  • Eligible counterparties – the “black belt” client exclusion from the rules
  • Scope and application of rules: Fair, clear and not misleading communications - revisited
  • Promotions
  • Client categories
    • MIFID II definitions
    • Retail clients
    • Elective professional clients
    • Per se professionals
    • Eligible counterparties
  • Complexity and risk of individual products: Past, Simulated & Future Performance Data
  • Direct Offers
  • Cold Calling
  • Approving Financial Promotions
  • Exercise: A real-life example to consider and evaluate

Introduction to the Advertising Standards Authority (Overview)

  • An independent body
  • What is its role?
  • ASA guidance
  • Non-compliant adverts
  • ASA complaints procedure
  • Latest rulings
  • Impact on financial promotions
  • Exercise: Reviewing ASA examples

CMCOB 3 – Rules for Claims Management Companies (Will be delivered subject to delegate demand)

  • What is Regulated Claims Management Activity
  • Fair, Clear & Not Misleading Rules
  • Identifying the Firm and prohibited statements
  • More Favourable Outcome Claim Prohibition
  • Prominent Statements about Making Claims Direct
  • Requirement to Name Ombudsman or Statutory Compensation Scheme
  • No Win, No Fee Rules
  • Termination Fees
  • Prohibition on Advertising in Certain Buildings Without Written Permission
  • Risk Warnings
  • Exercise: Reviewing a CMCOB 3 example

CONC3 (Will be delivered subject to delegate demand)

  • Definition
  • Application
  • APR’s
  • Representative Examples
  • Detailed provisions
  • Risk Warnings
  • Exercise: Reviewing a CONC 3 example

Part Two

Financial Promotions Regulation in Practice

  • The Rules – Refresher
  • Methodology
  • Reviewing, investigating, assessing
  • What to expect on an FCA visit
  • FCA’s approach to non-compliant promotions
  • Thematic reviews
  • Financial promotions using new media
  • Website promotions
  • Putting together a financial promotion
  • Common problems with FP’s
  • Exercise: Looking at COBS examples

Financial Promotions Using New Media

  • FCA View – 2015 – out of date and not terribly helpful
  • Dealing with unanswered questions which still spark debate
  • Definitions – Facebook, Twitter, Web, Blogs, Phone Applications
  • Sponsored Links
  • Image Advertising
  • Approval Process for New Media
  • Going Forward – the collective views of regulated firms
  • Exercise: A group review in detail of the Thematic Review and the final guidelines

FCA Approach to Motor Finance – Overview (will be delivered subject to delegate demand)

  • FCA Review – Final findings March 2019
  • Key Findings
    • Commission structures
    • Sufficient timely and transparent information
    • Lender controls
    • Affordability Assessment
    • Next steps
  • Representative Examples
  • Exercise: Looking at a motor finance promotion

FCA Linking Financial Promotions with Complaints Handling

  • Why is the FCA linking this with financial promotions?
  • What are the latest complaints handling rules?
  • Root Cause analysis
  • Liaising with FP approvers and the front line
  • Lessons learned
  • Holistic approach
  • FOS rulings
  • Exercise: Looking at recent FOS examples

Exceptions to the Rules

  • Is it wise to adopt an exceptions policy – the pros and cons
  • Impact of MiFID
  • Other exceptions

Record Keeping

  • Recording communications
  • Time periods
  • FP records requirements

Prominence & Financial Promotions

  • Thematic Review – now out of date and not always enforced
  • Digital Adverts
  • Space issues. Image advert or Financial Promotion
  • The customer “journey”
  • Recommended “default positions”

Course Conclusion

  • Summary
  • Open Forum


The trainer had a highly successful, long and varied “fast track” career in Lloyds Bank which led him to a very senior management position in the bank’s private banking and wealth management division at an early age. He was then “head hunted” to join a merchant bank to head the risk function at main board director level. He now has over 40 years’ experience in the UK banking and financial services sector.

The trainer has been a freelance Compliance, FCC & AML training consultant since retiring and is currently an external Master Trainer at both HSBC and Bank of China. At HSBC he has been a leading member of their Global FCC & AML training programme which is now entering its sixth year. He has created and delivered training to a vast range of clients, from global giants to small firms and partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, USA, South America, Europe, Africa, Asia and the Middle East.

He is a highly adaptive hands-on and highly sought-after facilitator who always receives excellent feedback. He is comfortable training at any level of seniority and experience from “black belts” downwards.  His expertise includes but is not limited to Risk ManagementTrade FinanceRegulatory ComplianceFCC & AML and all aspects of Corporate, Private & Retail Banking. He can deliver soft skills training, including train the trainer. He is also a subject matter expert in FinTech, Cryptocurrencies and ICO’s.

This trainer also teaches The Roles and Responsibilities of a Board Director and Client Relationship Management for Financial Services Firms.

Financial Promotions remain a very high-profile issue for the FCA and based on client feedback they are increasingly combining this with reviews of complaints handling procedures to ensure a joined-up process when it comes to marketing financial products to retail clients. Complaints are seen by the regulator as feedback from the client that something is wrong.  It is important that any lessons learned as a result are fed through to the financial promotions team.

Financial Promotions are the means by which customers are persuaded to buy, invest or use regulated financial products. For retail clients, it is important to remember the FCA guidance. The firm promoting the regulated product or service knows all about the product, its suitability, its strengths and weaknesses and whether it meets the needs of the applicant. The applicant/client does not have this knowledge (normally!) and it is entirely reasonable for the FCA to expect all regulated firms to recognise this imbalance and manage it accordingly.

Increasingly, social media and the internet are becoming key marketing platforms but promotion can be in almost any form via any media and all promotions must be clear, fair and not misleading and in many cases, this means exercising judgement. The list of products, investments and services that are now regulated by the Financial Promotions rules is wider than ever since the FCA took over consumer finance. The FCA expects all Financial Promotions for regulated activities to provide the prospective client with the information needed to make a clear and balanced judgement.

This Financial Promotions course provides participants with a comprehensive overview of the FCA approach and how it applies in practice. We cover the handling of complaints briefly in the context of the expected impact on promotions. We look at new media, prominence, image advertising, as well as good and bad practice in relation to financial promotions, including exceptions to the rules. There are examples of good and bad practice and the course points out some common pitfalls to be avoided.

Please Note: if requested in advance there is the option to add some specialised modules such as MCOB 3/ Funeral Plans / Motor Finance / Claim Handling / Leveraged Products etc.

  • I was looking for an overview of the financial promotions regulations with focus on up to date issues relevant to the products and services I work with. The course delivered this very well in the time frame available
  • Well paced. The trainer was very engaging and made the subject matter interesting. The content was presented in a clear and easy to understand way.
  • The course was well presented and the trainer answered all questions. He kept us engaged and answered all questions. Would definitely recommend the course. 
  • The trainer was fantastic and really engaging. The team had lots of positive things to say!
  • Mark was extremely engaging and made the topic interesting, this had a really positive impact and helped to deliver the important parts, he certainly prevented it from being boring or dry!
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Part 1
Number of places:
Part 2


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