Social Media & Comms

 In August 2014, the FCA consulted on their approach to the supervision of financial promotions in social media (GC14/6).

The finalised guidance on social media intends to help firms understand how they can use these media and comply with our rules. The FCA  also remind firms that our rules are intended to be media-neutral, to ensure that consumers are presented with fair and balanced information at each stage of the customer journey.

In response to some queries within the feedback from firms and industry bodies they have sought to clarify areas of the guidance and amended some of the text, as well as adding more visual examples.

The areas they sought to clarify were:

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 have 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 FCA 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 our existing requirements, which apply equally to social media, and risk management within the framework of SYSC (Senior Management Arrangements, Systems and Controls).

The guide is attached with this Bulletin and is well worth a read if you use this form of promotion. As they state it does have useful visual examples and being only 20 pages long will not take you long to refer too. Ultimately the benchmark to assess all promotions against is Clear, Fair and Not Misleading

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