The Financial Conduct Authority states clear communications are a key component of how firms apply Treating Customers Fairly (TCF) objectives in practice.
Of the six consumer outcomes that explain what the FCA wants TCF to achieve for consumers, the regulator states the following three are directly relevant to online financial promotions:
1) Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
2) Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
3) Consumers are provided with products that perform as firms have led them to expect.
Advisers should therefore consider what type of consumer the online listings and ratings service is targeting and whether their profile on a site is suitable. They should avoid anything that could be construed as promotion of a product, unless they are also willing to add in sufficient risk caveats.
On top of these regulatory requirements each online listing service will have its own requirements and rules, so Karen Barrett, chief executive of Unbiased, says advisers need to make sure they check the terms and conditions thoroughly.
In line with UK regulation, Ms Barrett says Unbiased requires firms to be authorised to dispense financial, mortgage or legal advice by the FCA, SRA or Law Society.
Lisa Beale, head of Checkaprofessional, says her service assesses itself against the Legal Services Consumer Panel’s standards for comparison websites.
The site also has a vetting process that requires advisersto provide proof of qualifications for their profession, evidence of professional indemnity insurance and references from clients and other professionals, such as their accountant.
She says her service is also registered by The Data Protection Act (ICO).