Financial Promotions

£550.00 +VAT

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This Financial Promotions course can also be presented face to face in-house or via live in-house webinar.

Financial Promotions Course Objectives:

  • Explain what the term Financial Promotion means
  • Understand why this is an important area for the FCA
  • Appreciate what clear, fair and not misleading means in practice
  • Consider the regulatory background
  • Consider the numerous best practice guidance publications (Thematic Reviews)
  • Explore the “rules” of financial promotions and exceptions
  • Consider the rules from your organsiations perspective, COBS 4, CONC 3 and/or MCOB 3A
  • Comply fully with the FCA regulation of financial promotions
  • Create clear, concise and compliant procedures
  • Know the difference between Real and Non-Real Time promotions
  • 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 an 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

Financial Promotions Course Content:

What is a Financial Promotion?

  • What is meant by this term?
  • Definition
  • Clear, fair and not misleading
  • In the ordinary course of business
  • Regulated activities
  • 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 the rules

What is the drive behind regulation

  • FCA view
  • 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
  • Treating Customers Fairly
  • Principles for Business
  • Clear, fair & not misleading in more depth
  • Targeting the right audience
  • Processes for excluding unsuitable applicants
  • Real time promotions
  • Non real time promotions

Exercise: A proposal for a promotion

The General “Rules”

  • How the FCA regulates
  • Who is affected?
  • Eligible counterparties
  • Scope and application of rule: retail and non retail financial promotions
  • Fair, clear and not misleading communications
  • Fair, clear and not misleading financial promotions
  • Retail clients
  • Past, Simulated & Future Performance Data
  • Direct Offers
  • Cold Calling
  • Approving Financial Promotions

Exercise: Considering an example

COBS 4

  • Definition
  • Application
  • Image Exceptions
  • Detailed provisions
  • Risk warnings

Exercise: Considering an example

CONC 3

  • Definition
  • Application
  • Image Exceptions
  • Detailed provisions
  • Risk warnings

Exercise: Considering an example

MCOB 3A

  • Definition
  • Application
  • Detailed provisions
  • Representative Examples

Exercise: Considering an example

Exceptions to the Rules

  • Is it wise to adopt an exceptions policy – the pro’s and cons
  • Impact of MiFID
  • Promotions to high net worth individuals
  • Promotions to sophisticated investors
  • Unregulated Collective Investment Schemes

FCA Regulation of Financial Promotions

  • Methodology
  • Reviewing, investigating, assessing
  • What to expect on a 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
  • Financial Promotions “Check lists”

Record Keeping

  • Recording communications
  • Time periods
  • FP records requirements

Financial Promotions Using New Media

  • FCA View – The thematic review in detail
  • Unanswered questions which still spark debate
  • Definitions – Facebook, Twitter, Web, Blogs, Phone Applications
  • Web Based
  • Sponsored Links
  • Image Advertising
  • Approval Process for new Media
  • Going Forward

Exercise: Considering an example

Prominence & Financial Promotions

  • Thematic Review – now out of date
  • Digital Adverts
  • Space issues. Image advert or Financial Promotion
  • The Customer “journey”
  • Recommended “default positions”

Exercise: FCA Case Studies on Financial Promotions

Course Conclusion

  • Summary
  • Open Forum

Background of the Trainer:

Your course director has spent more than 40 years in the banking and financial sector, much of it in a senior managerial/Director role.

He has delivered numerous public and in-house financial promotion courses to banks and other financial institutions and has watched with interest the subtle changes in approach to the topic as market practice and regulatory oversight have matured.  He is familiar with the methods of dealing with FP’s adopted by very large, medium sized and small firms.

He is a former Institute of Banking Lecturer, having gained distinctions in the exams. He is a subject matter aspect on all aspects of retail, corporate and global banking, including risk management and regulatory compliance. He has lectured extensively to both leading global financial institutions and to smaller bespoke specialists. He has delivered extensive programmes in all parts of the world including the USA, Europe, MENA, Africa and Hong Kong. He is currently an accredited Master Trainer at the world’s biggest global bank.

Financial Promotions Course Summary:

Financial Promotions remain a very hot topic for the FCA because they are the means by which customers are persuaded to buy, invest or use 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.

A 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 expect all Financial Promotions for regulated activities to provide the prospective client with the information needed to make a clear and balanced judgement.

This one day financial promotions course provides participants with a comprehensive overview of the FCA approach and how it applies in practice. It considers new media, prominence, image advertising, as well as good and bad practice in relation to financial promotions, including exceptions to the rules. It has many examples of good and bad practice and will challenge the participants to make judgements using examples which are more challenging. It and points out some common pitfalls to be avoided.

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Discounts

5-6 participants – 20% discount,7-8 participants – 25% discount,Over 9 participants – 30% discount

Select-your-course-date

11 October 2018, 19 March 2019, 10 September 2019