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News for Members

21 April 2015

FCA Social Media and Customer Communications Guidelines

Last year the FCA set out its approach to using social media for financial promotions.  In response to the queries received the FCA has now released their finished guidance in order to help firms to understand how they can harness its power whilst complying with the FCA's rules.

The CCA has summarised the key issues which were raised as part of the clarification process so that our members can ensure that their customers are presented with fair and balanced information at every stage of the customer journey.  The finished guidance covers the following:

  • Re-tweets, forwarding and sharing - what is perceived as a financial promotion and can this be done compliantly
  • Inserting images - clarification that the inducement and balancing statement/risk warning needs to be within an inserted image
  • ‘Click-through’ approach – a more detailed explanation of why the FCA has not taken this approach and the European Directive constraints they are subject to
  • Dynamic functionality – an explanation of how certain media are viewed as a whole for stand-alone compliance
  • ‘In the course of business’ - further explanation of the difference between personal and business-related posts/tweets
  • #Ad – an explanation of the FCA's stance on using hashtags to distinguish tweets as promotions and their use in general within financial promotional content
  • Approval and record-keeping – a reminder of the FCA's existing requirements, which apply equally to social media, and risk management within the framework of SYSC (Senior Management Arrangements, Systems and Controls)

 

To read the original paper, which includes some really useful examples of compliant and non-compliant tweets, banner ads and inserted images,  or to find out more about the issues for clarification, visit the FCA website.

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