Hi there 👋

We're excited to be working with you!

To help with your product design and marketing, we've put together standards that guide you through what you need to include 😊

Take a look at your relevant sections below and send your material for review to marketing@griffin.com. We can also answer questions at the same email address or via our Slack channel.

Let's get going!

Table of contents

1. Product specific marketing standards

    1.1 Our review process

    1.2 Collateral that needs our review and approval

    1.3 Easy access savings accounts

    1.4 Client money accounts

    1.5 Embedded bank accounts

    1.6 FAQs for all products

2. General marketing standards

3. Social media standards

Financial promotions

These standards do not account for approval of financial promotions. If you do not have the permission to approve your own financial promotions, as a part of the regulatory permissions granted to you by the FCA, please contact us.

1. Product specific marketing standards

1.1 Our review process

1. Send your material for review. Submit your marketing material to marketing@griffin.com Find out more details about expected review times in the table below. Pre-launch and launch marketing materials will need to approved by us.
2. Feedback and iteration. We will review your content and share our feedback within 5 working days. This process may have more than one iteration.
3. Approval. Once we are happy with your content, we will provide you with written approval. Your marketing material should not go live until you have received our written approval via email.
4. For updated content, repeat 1-3. If you are making changes to any content, please send the new mock ups to us for approval.
5. Product review. Prior to you going live, or if you're making significant changes to your product, we'll hold a final product review with you to go through the full end-to-end user journey. We'll typically do this on a 30-45 minute recorded call.

1.2 Collateral that needs our review and approval

Collateral that requires approval as part of being in partnership with Griffin.

1.3 Easy access savings accounts

(inclusive of bare trust savings)

Do's and don'ts

How to refer to Griffin

You must say that easy access savings accounts are:

provided by Griffin

You should signal that easy access savings accounts are provided by Griffin:

• in your app
• on your website product page(s) for easy access savings accounts
• the footer of balance statements
• in promotional emails about easy access savings accounts
• in your FAQs
• in social media posts
• over the phone

The above list is non-exhaustive and wherever you refer easy access saving accounts, you should mention that Griffin provide these accounts.

How to talk about Griffin's regulatory status

Please use the wording below:

Easy access savings accounts are provided by Griffin Bank Ltd ("Griffin"). Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

This needs to be used in the following places:

• The footer of your website page about savings accounts
• The footer of your emails sent to customers about savings accounts
• The footer of your balance statements

Examples of ways to describe easy access savings accounts

Grow your money/earn interest on your funds with competitive interest rates.

Deposit and withdraw funds at any time and easily access your money.

How to talk about withdrawing funds

Our current withdrawal schedule is:

For example, if a nested customers withdraws funds:

• At 11:59am on a working Monday, funds will be sent between 5-6pm the same day
• At 12:01pm on a working Monday, funds will be sent between 5-6pm the next day
• At any time on a Saturday, funds will be sent on Monday between 5-6pm

When talking about withdrawing funds, make sure you don't describe withdrawals as instant. Here are examples of what you can say:

Funds can be withdrawn at any time but withdrawals made after 12pm will take one working day to reach your account.

How to talk about interest rates

• Make it clear that the interest rate is variable and tracks the Bank of England base rate (which is subject to change).
• Refer to the Annual Equivalent Rate, or AER, i.e. what the customer could earn over a year.
  • Give examples on how the rate works. For example, if the interest rate is 3.00% AER and you deposit £1,000 and don't take any funds out, by the end of a 12-month period your balance will be £1,030.

• Interest accrues daily, but is paid into the easy access savings account on the first calendar day of the following month.
• If your customer closes their account at any point in the month, any accrued interest up to the date of closure will be paid out with the closing proceeds of the account.
  • Please note this does not apply to the bare trust savings. You will have your own account closing flow in that case.
• You need to list the interest rate in the following places‍—‌for more information see BCOBs 4 (2B):
  • on any paper or online statement of account provided
  • on your website‍—‌the first personalised page a customer accesses should show the interest rate
  • within your app, list the interest rate on your account page
  • in any communications about changes in interest rate or expiry of promotional interest rates

The interest rate can also be listed in your other marketing material but it must be in the above pieces of collateral.

• If the interest rate changes due to a change in your commercial terms with Griffin (i.e., independent of base rate change) you will need to notify customers with at least 14 days' advance notice.

How to talk about promotional interest rates

• When offering a promotional interest rate, always give an explanation of the circumstances in which the promotional rate applies, what the promotion is, and when it will end. For e.g., "Your savings account interest rate of 5% AER (variable) includes a promotion of 1% AER. This rate will expire on [specified date] after which your interest rate will be 4% AER (variable)."
• An explanation of the promotional interest rates should always be mentioned in the savings summary box.
• You should highlight that the interest rate offered is a temporary promotion on:
  • Any statement of accounts
  • Your website
  • On the account page

When highlighting this in-app or online, link out to an explanation of the promotional rate.

• You must notify customers, in writing or through another durable medium, in advance of the promotional interest rate ending.

How to talk about FSCS protection

Please use the wording below:

Easy access savings accounts are provided by Griffin Bank Ltd (Griffin). As Griffin is a UK bank, your funds are protected by the Financial Services Compensation Scheme (FSCS), the UK's deposit guarantee scheme. The FSCS covers eligible deposits of up to £85,000 per depositor.

It's important to note that £85,000 is the maximum compensation you will receive across all bank accounts you hold with Griffin. If you deposit funds with Griffin via [insert product], and also deposit funds in a different account with Griffin via [insert product] or another provider that is also powered by Griffin, you will still only receive a maximum of £85,000 in compensation. Visit Griffin's website to learn more about deposit protection.

This wording needs to be used whenever you refer to easy access savings accounts:

• As a prominent section on your website page about easy access savings accounts
• On your account statements
• In your support centre

You can find the FSCS protection leaflet here for any customers that ask for it.

FSCS protection in advertising

Relevant link: PRA rulebook Chapter 18

Within advertising, you should only mention if the product is or is not covered by FSCS. You can't provide further information in advertising materials.

FSCS information sheet and exclusions list

Relevant link: PRA rulebook chapter 16

For both easy access and bare trust savings, you must distribute to and store acknowledgement of our FSCS information sheet and exclusions list from your customers. The information sheet and exclusions list can be downloaded from our deposit protection page.

Before customers enter into a contract

• You must provide the FSCS information sheet and exclusions list to customers before entering into a contract.
• The customer needs to acknowledge they have read the FSCS information sheet and exclusions list before entering into a contract.
  • You can obtain acknowledgement through a signature or via a 'tick box' in the account opening flow.
• You must store these acknowledgements following the same process you use for other commercial documents.

Keeping customers up to date

• You must provide a copy of the FSCS information sheet and exclusions list to customers at least annually.
• If a customer requests the sheet on paper you will need to provide this to them and can't charge for it.

The savings summary box

Relevant links: FCA Handbook BCOBS 2.2A

The savings summary box template can be found in this folder (link here). Make a copy to create your own version.

The savings summary box must be included in your account opening flow‍—‌before the customer signs a contractual agreement with you.

Communicating the summary box

• Website‍—‌the savings summary box has to be listed on your website's savings account product page.
• App‍—‌you must provide the savings summary box within your app and it must be downloadable (it is not sufficient to link out to a website page with the summary box).
• Phone‍—‌if you are communicating over the phone about the savings account, the information from the savings summary box must be communicated orally using clear, easily understandable language (except for the information in the row that includes the heading "What would the estimated balance be after [x] months based on a £[x] deposit?")
• Paper‍—‌if you are communicating in person and using written paper to promote the savings account you must provide the savings summary box on a separate sheet.
• Any direct financial offer‍—‌promotions in relation to a savings account should include the savings summary box.

Contents of the summary box

• The summary box may relate to more than one savings account provided that the information in relation to each respective account is presented in a separate column and is clearly distinguishable from information in relation to other accounts
• Any additional information you choose to provide on the savings account must be provided outside of this summary box
• You may also want to include a statement in close proximity to the summary box that explains that the information provided in it is a summary of the key features of the savings account and is not intended to be a substitute for reading the account's terms and conditions

What happens to the savings summary box after an interest rate change?

You must update the savings summary box if the interest rate changes‍—‌either due to a change in the Bank of England base rate or a change in the agreed-upon margin with Griffin. Once updated, you must notify customers of the change.

Statements of accounts

• You must regularly provide customers with a statement of accounts (free of charge) on paper or any other durable medium, unless you meet one of the exceptions laid out in the BCOBs 4.2.1(1)
• You must provide customers with statements of accounts upon request
• You can only charge your customer for statements if they request additional information or ask for statements more frequently than usual and any such charge must reasonably correspond to your actual cost
• Ensure that your statement of accounts include the appropriate FSCS disclaimers
• If a statement of account has been requested by your customer, you will need to provide this to them within a reasonable period of time following the request

FSCS disclaimers in statement of accounts

Relevant link: PRA rulebook chapter 17

If you are providing statement of accounts, you need to:

Confirm that the deposits are eligible (if that is the case) using the below wording:

Your easy access savings accounts are provided by Griffin Bank Ltd ("Griffin"). Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

Your deposits listed on this statement of accounts are eligible for protection under the Financial Services Compensation Scheme (FSCS) up to a total of £85,000 per depositor. It's important to note that £85,000 is the maximum compensation you will receive across all bank accounts you hold with Griffin. The FSCS compensate it's depositors if a bank can't meet its financial obligations. The FSCS information sheet and exclusions list will be given to you once a year but you can find it {INSERT WHERE}. For further information about the compensation provided by the FSCS, refer to the FSCS website at www.FSCS.org.uk.

• Include a reference to the FSCS information sheet and exclusions list.

FAQs

Can we use other names‍—‌like "pots", "vaults" or "jars" - to refer to easy access savings accounts?

Yes, you can brand easy access savings accounts as "pots", "vaults" or "jars" - as long as it is clear that the underlying bank account is provided by Griffin. This should be reflected in the T&Cs you issue to your customers. If you want to use a different name, please check with us.

Can funds be accepted from anywhere?

No, funds can only be accepted from UK bank accounts.

Who is eligible for an easy access savings account?

To qualify for an easy access savings account, your customer must be:

• an individual, limited company, or sole trader
• be a UK resident and pay tax in the UK
• be over 16 years old, if they are an individual

Griffin will not provide bank accounts to companies that operate in or have connections to certain industries. For more detail, see our eligibility criteria.

What if one of my customers wants to complain about their easy access savings accounts?

If one of your customers has a complaint and you believe Griffin is fully or partially at fault, please forward us the complaint and we will follow the process set out in our complaints standard.

1.4 Client money accounts

How to refer to Griffin

You can reference Griffin as the bank you use to deposit client money. In the context of how funds are kept safe or in your terms and conditions, please refer to us by our full company name, "Griffin Bank Ltd."

How to talk about Griffin's regulatory status

Please use the wording below:

Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

If you're using embedded client money accounts, this needs to be used in the following places:

• The footer of your website page about client money accounts
• The footer of any emails sent to customers about client money accounts
• The footer of your balance statements

How to talk about FSCS protection

Eligible deposits of up to £85,000 per depositor are covered by the Financial Services Compensation Scheme (FSCS), the UK's deposit guarantee scheme. Visit Griffin's website to learn more about deposit protection.

You can find the FSCS protection leaflet here for any customers that ask for it.

FSCS protection in advertising

Relevant link: PRA rulebook Chapter 18

Within advertising, you should only mention if the product is or is not covered by FSCS. You can't provide further information in advertising materials.

FSCS information sheet and exclusions list

Relevant link: PRA rulebook chapter 16

You must distribute to and store acknowledgement of our FSCS information sheet and exclusions list from your customers. The sheet can be downloaded from our deposit protection page.

Before customers enter into a contract

• You must provide the FSCS information sheet and exclusions list to customers before entering into a contract.
• The customer needs to acknowledge they have read the FSCS information sheet and exclusions list before entering into a contract.
  • You can obtain acknowledgement through a signature or via a 'tick box' in the account opening flow.
• You must store these acknowledgements following the same process you use for other commercial documents.

Keeping customers up to date

• You must provide a copy of the FSCS information sheet and exclusions list to customers at least annually.
• If a customer requests the sheet on paper you will need to provide this to them and can't charge for it.

How to talk about interest rates

• Make it clear that the interest rate is variable and tracks the Bank of England base rate (which is subject to change).
• Refer to the Annual Equivalent Rate, or AER, i.e. what the customer could earn over a year.
  • Give examples on how the rate works. For example, if the interest rate is 3.00% AER and you deposit £1,000 and don't take any funds out, by the end of a 12-month period your balance will be £1,030.

• Interest accrues daily, but is paid into the client money account on the first calendar day of the following month.
• If your customer closes their account at any point in the month, any accrued interest up to the date of closure will be paid out with the closing proceeds of the account.
  • Please note this does not apply to the bare trust savings. You will have your own account closing flow in that case.
• You need to list the interest rate in the following places‍—‌for more information see BCOBs 4 (2B):
  • on any paper or online statement of account provided
  • on your website‍—‌the first personalised page a customer accesses should show the interest rate
  • within your app, list the interest rate on your account page
  • in any communications about changes in interest rate or expiry of promotional interest rates

The interest rate can also be listed in your other marketing material but it must be in the above pieces of collateral.

• If the interest rate changes due to a change in your commercial terms with Griffin (i.e., independent of base rate change) you will need to notify customers with at least 14 days' advance notice.

Statement of accounts

Relevant link: PRA rulebook chapter 17

If you are providing customers with statement of accounts:

• Ensure that your statement of accounts include the appropriate FSCS disclaimers
• Confirm that the deposits are eligible (if that is the case) using the below wording:

Your client money accounts are provided by Griffin Bank Ltd ("Griffin"). Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

Your deposits listed on this statement of accounts are eligible for protection under the Financial Services Compensation Scheme (FSCS) up to a total of £85,000 per depositor. It's important to note that £85,000 is the maximum compensation you will receive across all bank accounts you hold with Griffin. The FSCS compensate it's depositors if a bank can't meet its financial obligations. The FSCS information sheet and exclusions list will be given to you once a year but you can find it {INSERT WHERE}. For further information about the compensation provided by the FSCS, refer to the FSCS website at www.FSCS.org.uk.

• Include a reference to the FSCS information sheet and exclusions list.

1.5 Embedded bank accounts

How to refer to Griffin

You must say that these accounts are:

provided by Griffin

You should signal that the accounts are provided by Griffin:

• in your app
• on your website product page(s)
• the footer of balance statements
• in promotional emails
• in your FAQs
• in social media posts
• over the phone

The above list is non-exhaustive and wherever you refer to embedded bank accounts, you should mention that Griffin provide these accounts.

How to talk about Griffin's regulatory status

Please use the wording below:

Your [insert name of account] accounts are provided by Griffin Bank Ltd ("Griffin"). Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

This needs to be used in the following places:

• The footer of your website page
• The footer of your emails sent to customers about savings accounts
• The footer of your balance statements

How to talk about FSCS protection

Please use the wording below:

Eligible deposits of up to £85,000 per depositor are covered by the Financial Services Compensation Scheme (FSCS), the UK's deposit guarantee scheme. Visit Griffin's website to learn more about deposit protection.

This wording needs to be used whenever you refer to the embedded operational accounts:

• On your website page
• On your account statements
• In your support centre

You can find the compensation leaflet here for any customers that ask for it.

FSCS protection in advertising

Relevant link: PRA rulebook Chapter 18

Within advertising, you should only mention if the product is or is not covered by FSCS. You can't provide further information in advertising materials.

FSCS information sheet and exclusions list

Relevant link: PRA rulebook chapter 16

You must distribute to and store acknowledgement of our FSCS information sheet and exclusions list from your customers. The sheet can be downloaded from our deposit protection page.

Before customers enter into a contract

• You must provide the FSCS information sheet and exclusions list to customers before entering into a contract
• The customer needs to acknowledge they have read the FSCS information sheet and exclusions list before entering into a contract.
  • You can obtain acknowledgement through a signature or via a 'tick box' in the account opening flow.
• You must store these acknowledgements following the same process you use for other commercial documents.

Keeping customers up to date

• You must provide a copy of the FSCS information sheet and exclusions list to customers at least annually.
• If a customer requests the sheet on paper you will need to provide this to them and can't charge for it.

Statement of accounts

Relevant link: PRA rulebook chapter 17

If you are providing customers with statement of accounts:

• Ensure that your statement of accounts include the appropriate FSCS disclaimers
• Confirm that the deposits are eligible (if that is the case) using the below wording:

Your accounts are provided by Griffin Bank Ltd ("Griffin"). Griffin is a company registered in England and Wales (No. 10842931). Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

Your deposits listed on this statement of accounts are eligible for protection under the Financial Services Compensation Scheme (FSCS) up to a total of £85,000 per depositor. It's important to note that £85,000 is the maximum compensation you will receive across all bank accounts you hold with Griffin. The FSCS compensate it's depositors if a bank can't meet its financial obligations. The FSCS information sheet and exclusions list will be given to you once a year but you can find it {INSERT WHERE}. For further information about the compensation provided by the FSCS, refer to the FSCS website at www.FSCS.org.uk.

• Include a reference to the FSCS information sheet and exclusions list.

1.6 FAQs for all products

How should we describe Griffin to our customers?

Please refer to Griffin as your bank, banking partner, or banking provider. See our General Marketing Standards for a boilerplate on how to describe Griffin.

What is the process for dealing with fraud?

If you need to report a fraud claim, please email support@griffin.com as soon as possible. We will acknowledge within one working day and then start investigating the claim.

Can we link to your website?

Of course! Here is our website link: https://griffin.com/

Can we use your logo on our website?

Yes! You can find our logos here and we're happy to share our brand guidelines with you.

2. General marketing standards

Describing Griffin

It may be helpful to your customers to understand who we are, what kind of products we provide, and how working with us benefits them. We suggest adapting the following boilerplate to suit your needs:

Griffin is a UK bank that exists to help other companies embed banking capabilities into their own products and services. Money you hold with us is deposited into a bank account with Griffin, where it is ringfenced from our operating funds and protected under the FSCS where applicable.

But Griffin doesn't just offer bank accounts: they have a purpose-built technology platform that makes it simple for us to integrate those bank accounts into our own offering. Griffin's compliance technology also means we can quickly approve and onboard new customers. Once a new customer has been approved, we can automatically open a dedicated bank account to hold their money, which makes tracking funds and moving money faster, easier, and less prone to error. Learn more at griffin.com.

Griffin Bank Ltd is registered in England and Wales with company number 10842931. Griffin is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Griffin's firm reference number is 970920.

Do's and don'ts

Sample language

✅ We're proud to announce we are launching a new banking solution in partnership with Griffin.

✅ We're your number one provider for easy access savings accounts, powered by Griffin.

✅ We're delighted to be working with Griffin.

⛔ We're proud to announce that we are launching a new banking solution.

⛔ We're your number one banking provider for easy access savings accounts.

⛔ We're delighted to be working with Griffin Bank.

FAQ

Do we have to include Griffin's regulatory status on our website and comms?

No, you don't. Please link out to our website where relevant so your customer can find out more about us if they wish.

Can we use your logo on our website?

Yes! Just send us your mockup :)

Can we say we offer FSCS-protected accounts?

Where applicable, FSCS protection is per depositor as opposed to per account, so it is not accurate to say that a bank account is "FSCS-protected". However, you can say that "eligible deposits are protected by the FSCS". There are limits and conditions on FSCS coverage, and this should be noted where relevant. Learn more about deposit protection.

Can we use the FSCS logo on our website?

We don't own the FSCS logo. Please check the FSCS's own terms and conditions of usage. UK firms authorised by the PRA and/or FCA have express permission to use the logo to promote products or services covered by the FSCS. If you are not an authorised firm, you must get written permission from the FSCS.

Can we have a dedicated page for Griffin on our website?

No, please link to www.griffin.com where relevant instead.

Can we provide a contact email for Griffin on our website, or send our customers directly to Griffin with their queries?

As set out in our Customer Success Standards, we have no direct relationship with your customers and so any support they need should be provided through your own channels. We're happy to advise your team if a customer query relates to one of our products, and we can work with you to develop FAQ content if necessary. If one of your customers has a complaint and you believe Griffin is fully or partially at fault, please forward us the complaint and we will follow the process set out in our complaints standard.

If your customer has general queries about Griffin, please direct them to our help centre.

3. Social media standards

These are our social media guidelines that need to be followed for accounts being provided by Griffin. Above you will find the wording you need to use and how to talk about our accounts. These should be read in conjunction with these standards.

Whilst these social media standards are designed to be helpful and specific to Griffin, they do not replace the full FCA guidelines on financial promotions on social media which can be found here. Please read these in full 🙂.

What channels fall under these guidelines?

As defined by the FCA:

Social media share the characteristic of being digital and can be defined as 'websites and applications that enable users to create and share content or participate in social networking' (Oxford Dictionaries 2013). The following is a non-exhaustive list:

• blogs
• microblogs (X)
• social and professional networks (Facebook, LinkedIn, Google+)
• forums
• image and video-sharing platforms (YouTube, Instagram, TikTok, Pinterest, Snapchat)

Our review process

1. Share your social media plan at least one month before launch. Include the channels you will be using, your plan for launching the savings account and ongoing promotions prior to launch.
2. Send your material for review. Submit your material via email to marketing@griffin.com at least one month prior to making it public. Content that needs approval is below.
3. Feedback and iteration. We will review your content and share our feedback within 5 working days. This process may have more than one iteration.
4. Approval. Once we are happy with your content, we will provide you with written approval. Your social media content should not go live until you have received our written approval via email.
5. For updated social media content, repeat 1-3. If you are making changes to any content, please send the new mock ups to us for approval.
6. Spot checks quarterly. We will spot check your social channels on a quarterly basis to make sure the guidelines are being followed
7. Record-keeping and approvals. You will also need to keep a record of all savings account social media posts and who in your business approved these. We have created a template below you can use which will be saved in our shared notion page. This information will be used for spot-checking.

Collateral that needs review and approval

Key points of the guidance

1. Prominence

   • Information that is required to be prominent should be presented in a way that is easily identified and understood by consumers, equipping them to make effective, timely and properly informed decisions.

2. Fair, clear, and not misleading communications

   • All financial promotions must meet the standards of being fair, clear, and not misleading. This requirement is technology-neutral and applies across all channels, including social media.

3. Balance of information

   • Promotions should provide a balanced view of both the benefits and risks associated with the financial products and services being promoted. This ensures consumers can make well-informed decisions.

4. Target audience consideration

   • Firms should account for the broad reach of social media. Promotions should remain compliant and clear even if shared beyond the intended audience.

5. Character-limited media

   • When using character-limited platforms (e.g. X), firms must ensure that essential information is not omitted. Any mandatory messages that need to appear in a certain format should not be manipulated by omitting characters or using synonyms if the regulatory wording is prescriptive. Using images or infographics to convey detailed information within such limitations is recommended.

6. Required statements

   • Required statements must be included in promotions. These should be clear and prominent, even on character-limited platforms. Any mandatory messages that need to appear in a certain format should not be manipulated by omitting characters or using synonyms if the regulatory wording is prescriptive.

7. Stand-alone compliance

   • Each individual communication must comply with regulatory standards. For example, each post on X must be independently compliant.

8. Unsolicited promotions

   • Firms must comply with specific legal requirements when sending unsolicited promotions via electronic media. This includes adhering to rules around cold calling and unsolicited real-time promotions.

9. Approval and record-keeping

   • Firms must have systems in place to ensure proper sign-off on digital media communications by a competent and senior person. Adequate records of all promotions must be maintained. The final content should be record-kept. You shouldn't rely on the social media channel to maintain records of the content.

10. Use of influencers

    • Influencers promoting regulated financial products must ensure that their communications are approved by an FCA-authorised person. Unauthorised promotion of financial products can lead to criminal offences. You will remain responsible for the compliance of every promotion the influencer makes and you should take appropriate steps to ensure the influencer used understands the product they are promoting and is aware of relevant regulatory requirements.

Checklist

Under the Consumer Duty (the Duty), financial promotions must support retail customer understanding and communicate information to retail customers in a way that equips them to make effective decisions. You need to consider this Guidance alongside your obligations under the Duty to deliver good outcomes for retail customers.

When creating any financial promotions content for digital channels this checklist should help you in making sure the content is compliant.

Record-keeping and approval template