Compliance Blog

How to communicate compliantly with an ageing population

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September’s Regulation Round-up, a monthly update from the Financial Conduct Authority, has as its hot topic on how to communicate compliantly with an ageing population.

For some time now, the regulator has been concerned about the changing demographic – the growth in the number of older people and the way the financial services industry interacts with them.

Work on this began in February, when it launched a discussion paper on Ageing Population and Financial Services. The discussion paper has received over 50 written responses, and the regulator has met with some of the interested stakeholders to talk about current practice.

This has helped to inform a programme of work, which will see the Authority collaborate with the industry to deliver ‘positive, lasting change for older people’. This week, the regulator has published an update on its progress.

What does this mean for financial promotions compliance?

The ageing population will impact compliance, particularly around marketing and communications.

The FCA update published this week focuses on several areas. Some are especially relevant to marketing:

  • Advice and guidance
  • Smarter Consumer Communications

Advice and guidance

Making sure that products and services are appropriate is essential. Not just for older consumers, but for customers as a whole. But the potential vulnerability of older consumers makes this a particular area of focus.

Products need to be suitable (our blog on the FCA’s push for suitability has tips on how firms can deliver this).

Treating Customers Fairly is another major theme, with six consumer outcomes the regulator wants to see achieved.

And the focus isn’t all on sales materials and new customers. Existing customers need to be treated fairly too. The Authority made this clear in its call for insurers to raise their game around renewals communications.

Smarter consumer communications

The FCA launched its Smarter Consumer Communications initiative in June 2015. The aim was to encourage firms to think about the ways they communicate, and encourage them to use more innovative approaches where appropriate.

This might include increasing the amount of digital communications.

There are compliance implications here, as it’s often assumed that digital marketing – websites, emails, social media – doesn’t need the same level of governance as printed materials.

This isn’t the case.

Any digital marketing activity requires exactly the same level of review, approvals, compliant audit trail and record-keeping as printed ones.

Ensuring your social media, web content and other digital activity meets the requirements is essential. 

Our ’10 dos and don’ts for FCA-compliant Twitter’ has more advice on how to ensure you deliver what’s required.

What happens next?

The update sets out some next steps relating to the ageing population project:

The regulator:

  • Aims to publish a Feedback Statement during the autumn to outline the feedback received in response to the Smarter Consumer Communications Discussion Paper and explain its next steps.
  • Will launch its Ageing Population Strategy in summer 2017. Input from our stakeholders will continue to be gathered in the meantime, via one-to-one meetings and roundtables on key issues.

Any firm wanting to offer comments or contribute to the programme can email dp16-01@fca.org.uk to have their say.

What do Compliance teams need to do?

You need to make sure your financial promotions – whether aimed at an older audience or anyone else – adhere to the guidelines. Taking a look at the Treating Customers Fairly rules is a good place to start.

Follow the guidance on how customers should be treated and you will be on the front foot when it comes to avoiding compliance breaches and minimising risk.

You can get a step ahead by downloading a copy of our TCF FAQs.

Find out how to make sure your marketing materials make the grade. The FAQs document is free to download – you can get your copy here.

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