If you will be advertising any financial retail products and they are PCP, HP etc and you are quoting a monthly payment, it triggers the requirement of a full finance representative finance example (the information is below). CONC 3.5.3 R (1) Where a financial promotion indicates a rate of interest or an amount relating to the cost of credit whether expressed as a sum of money or a proportion of a specified amount, the financial promotion must also: (a) include a representative example in accordance with CONC 3.5.5 R.
All of the information needs to be shown with equal prominence.
If you have shown the availability of finance, you must confirm you are acting as a credit broker and not a lender, along with your business address. - Red.
If you have any statements such as "low finance available" this triggers the requirement for a representative finance example.
The exception is a 0% APR product that has different requirements. However, with a 0% APR, you will need to ensure the finance product name is displayed with the APR.
If it is a text-only post, you will need to add all the financial information and AR disclosure information. All of the text in the post must be clear and easy to read and understand (please note the device the post is viewed on will impact the quality of the information); the finance payment must not be more prominent than any other information included in the post. - Red.
If it is a photograph post, you would need to add the text to the photograph. We are aware of the impact on promoted Facebook posts where an image has more than a percentage of text within the pixels.
The following information is needed for a representative example (please note this is not exhaustive):
- Product name
- vehicle price
- Monthly payment
- Deposit
- Representative APR
- Fixed interest rate
- Duration/term of the agreement
- Final optional payment
- The total amount of credit
- The Total amount payable
- Any applicable fees
Credit broker statement and business address and all of the information needs to be shown with equal prominence.
The most recent FCA guidance can be found here: http://y7a5w.videomarketingplatform.co/financial-promotion-videocredit-v4
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