Introduce a clear policy
Put in place a policy that reflects your Firm’s approach and risk tolerance. Compliance sign-off of promotional and borderline promotional communications is always going to be seen as good practice.
Educate your colleagues
To aide and assist Compliance in their duties ensure that everybody who is in the “loop” of the issuance of a Financial Promotion is fully trained and competent to do so. This may sound like stating the obvious – but genuinely you would be surprised at how little some authors of Financial Promotions know and understand about this area (Training and Development).
Keep your online profiles, policies and procedures up to date
Make sure that IT or the author or the Department Head tidies up your online profile and footprint on a regular basis. This will help to mitigate and delete any out of date information on your web-site or online profile.
Compliance may wish to include in their Compliance Monitoring Plan a test to regularly monitor online Fin Proms which will (or should) help to identify any posts that got through your new watertight policy and procedures so that you can adapt as necessary.
Firms must ensure that all digital media communications are signed off in accordance with COBS 4.10.2.R and maintain adequate records of all such communications.
It is clear from the consultation that the FCA understands that social media is becoming a medium of choice to communicate with customers and, to meet the objectives of consumer protection and effective competition, it is essential that all firms using social media consider the relevant FCA guidance and rules.