The FCA published the quarterly financial promotions data for Q3 2021 setting out the number of financial promotions that have been amended or withdrawn due to non-compliance with the various financial promotions rules for 2021 Q3. In total, the FCA reviewed 514 financial promotions in Q3 2021. The reviews were triggered by both complaints the FCA received and the FCA’s proactive supervision work to ensure that financial promotions meet the rules including that they are fair, clear and not misleading. As a result of the FCA’s supervision work, there were 26 cases that resulted in 74 financial promotions being amended or withdrawn. Interestingly, as illustrated in the below chart published by the FCA, the sector with the highest number of financial promotions cases in Q3 2021 was retail lending.
The retail lending sector includes consumer credit lenders, credit brokers and debt service providers. We recommend that firms operate a process whereby financial promotions are subject to an internal compliance review and approval prior to publication. In addition, we recommend that firms periodically review their publicly communicated financial promotions to ensure that they remain suitable vis-à-vis, for example, changes in business model or product strategy.