I see where Andrew Oliver, the adviser suggesting this, is coming from.
It has long struck me that many of the marketing and promotional techniques used by some of the biggest lead generation companies are not techniques that we would be able to get compliance approval for as they do not fit with the rule book.
While I do not think that lead generation firms should be regulated as such, I feel their marketing techniques for generating the leads should fall under the same rules advisory firms play under and be enforceable against the lead generator.
As I understand it at present the lead purchaser, usually an IFA or mortgage broker is the person enforcement action would be taken against if the marketing activity used to generate the lead was found to breach rules – as the FCA would consider the lead purchaser to have outsourced his marketing. I do not think many advisers realise this.
I have not used lead firms for many years for this reason, it is simply not possible for me to 100 per cent vet how they generate their leads – for understandable reasons they do not want to tell me their secrets.
If I could be assured responsibility for how the lead was generated lay with them I would be tempted to start using them again. It would probably also lead to more responsible practices from the rogue outliers.
IFA, Bloomfield Financial
Houghton Le Spring, Tyne and Wear