The FCA stated that despite its letter, it has identified a number of examples where it appears the due diligence carried out on a financial promotion may have fallen well short of the standard it expects.
In addition, the FCA reminds firms that:
- before a firm approves a financial promotion for communication by an unauthorised person, it must confirm that the promotion complies with the financial promotion rules;
- if at any time they become aware that the financial promotion no longer complies with the rules, it must withdraw its approval;
- a firm that communicates or approves a financial promotion must have put in place adequate systems and controls, or policies and procedures; and
- they must ensure that information presented is accurate and always gives a fair and prominent indication of any relevant risks when referencing any potential benefits.