Prominence
What is meant by ‘prominence’ in financial promotions?
The FCA states under CONC 3.2.3G:
“Information or a statement included in
a financial promotion or communication
will not be treated as prominent unless
it is presented, in relation to the other
content of the financial promotion or
communication, in such a way that it is
likely that the attention of the average
customer to whom the financial
promotion or communication is directed
would be drawn to it.”
The financial promotion needs to be clear, fair and not misleading to the customer group that the promotion is directed at.
Consideration should be made to the layout of the financial promotion, e.g. positioning and size of text, background and colour.
The representative APR must be given no less prominence than any statement or incentive that triggers the requirement for it to be shown on the promotion, as required under CONC 3.5.7R (2). The same applies to the representative example, which also must be given no less prominence as any information relating to the cost of credit, in order to comply with CONC 3.5.5R (5)(d).
