Five years ago the Financial Conduct Authority published their finalised guidance for Financial Promotions, containing detailed protocols for the prominence of risk warnings. These risk warnings must run alongside anything that is regarded as a financial promotion.
We love financial planning and how we can help our clients understand, achieve and maintain their desired lifestyle. We like to write blogs about it.
Unfortunately we have run into a technical problem which we hope an experienced webdesigner can help with.
We need a solution that will allow us to keep blogging whilst maintaining the prominence of risk warnings. More details can be found by reading the guidance paper and you can download a copy here.
These are the elements that a webdesigner needs to take into consideration:
1. Jill Turner Associates are an appointed representative of Intrinsic Financial Planning, a network of small and large financial advice firms. Intrinsic Financial Services and our regulator the Financial Conduct Authority interpret a blog written by someone authorised to conduct investment business as a financial promotion, especially when there is a comment section or a contact form which can be regarded as an inducement to get in touch for further guidance.
2. Now this is not a problem if the risk warnings are prominently displayed, in the same font, the same size and at the beginning of every blog article.
3. You can read the main risk warnings in the side bar accompanying this page.
4. One of the drawbacks to blogging is being able to capture your readers attention in the first one or two lines, you have lost the reader. How does this impact if these lines are risk warnings ?
5. We thought a solution was maybe to include the risk warning in the side bar, it would seem that whtever blog article the reader landed on the risk warnings would be in the sidebar. BUT... they disappear from the sidebar when the reader scrolls down whilst reading the article.
6. Pop up boxes with risk warnings are not allowed.
7. The advice has been that the following risk statements would need to feature directly at the top of the page, on separate lines from one another and in the same font and text style as the rest of the main blog content included within the page, in order to correspond with the FCA’s requirements on prominence -
8. We are using Weebly at the moment for blogging and I think there maybe a fundamental issue with using Weebly for the blogs as the blogs scroll into each other with upto 10 on a page and this is the advice we have been given is:
" The above notwithstanding, the key issue relates to the fact that were the reader to simply scroll down the blog page, rather than instead clicking on the title of each blog in order that the individual blog then opens in a new window, the risk statements would remain at the top of the page, and therefore insufficiently prominent. Instead, the risk warnings should either remain fixed on the screen even when the customer scrolls up and down the blog page, or should be repeated further down the page next to each blog.
Given that I appreciate this may be difficult from a formatting perspective, my suggestion would therefore be to simply include the titles of each of these blogs on the main blog page, rather than have all the content on the main page. The reader can then click on each of the titles, which will take them to an individual page related to each blog, at which point the risk statements will then be included prominently in their current position. By making such amendment, this would then mean that we could sign the website off as being, as the risk statements contained within the blogs pages would then be sufficiently prominent."
9 . Maybe it might work if the blog is limited to one per page.
10. Anyway we are in agreement that the risk warnings are there to protect the public and help to differentiate regulated advice firms from non - regulated advice firms. We are hoping that we can find a solution that allows us to engage with readers whilst complying with the rules and not losing engagement.
CAN YOU HELP?
We love financial planning and how we can help our clients understand, achieve and maintain their desired lifestyle. We like to write blogs about it.
Unfortunately we have run into a technical problem which we hope an experienced webdesigner can help with.
We need a solution that will allow us to keep blogging whilst maintaining the prominence of risk warnings. More details can be found by reading the guidance paper and you can download a copy here.
These are the elements that a webdesigner needs to take into consideration:
1. Jill Turner Associates are an appointed representative of Intrinsic Financial Planning, a network of small and large financial advice firms. Intrinsic Financial Services and our regulator the Financial Conduct Authority interpret a blog written by someone authorised to conduct investment business as a financial promotion, especially when there is a comment section or a contact form which can be regarded as an inducement to get in touch for further guidance.
2. Now this is not a problem if the risk warnings are prominently displayed, in the same font, the same size and at the beginning of every blog article.
3. You can read the main risk warnings in the side bar accompanying this page.
4. One of the drawbacks to blogging is being able to capture your readers attention in the first one or two lines, you have lost the reader. How does this impact if these lines are risk warnings ?
5. We thought a solution was maybe to include the risk warning in the side bar, it would seem that whtever blog article the reader landed on the risk warnings would be in the sidebar. BUT... they disappear from the sidebar when the reader scrolls down whilst reading the article.
6. Pop up boxes with risk warnings are not allowed.
7. The advice has been that the following risk statements would need to feature directly at the top of the page, on separate lines from one another and in the same font and text style as the rest of the main blog content included within the page, in order to correspond with the FCA’s requirements on prominence -
- The value of pension and investments can fall as well as rise. You may get back less than you invested.
- Tax treatment varies according to individual circumstances and is subject to change.
- The Financial Conduct Authority does not regulate on Estate Planning.
- Your home may be repossessed if you do not keep up repayments on your mortgage.
8. We are using Weebly at the moment for blogging and I think there maybe a fundamental issue with using Weebly for the blogs as the blogs scroll into each other with upto 10 on a page and this is the advice we have been given is:
" The above notwithstanding, the key issue relates to the fact that were the reader to simply scroll down the blog page, rather than instead clicking on the title of each blog in order that the individual blog then opens in a new window, the risk statements would remain at the top of the page, and therefore insufficiently prominent. Instead, the risk warnings should either remain fixed on the screen even when the customer scrolls up and down the blog page, or should be repeated further down the page next to each blog.
Given that I appreciate this may be difficult from a formatting perspective, my suggestion would therefore be to simply include the titles of each of these blogs on the main blog page, rather than have all the content on the main page. The reader can then click on each of the titles, which will take them to an individual page related to each blog, at which point the risk statements will then be included prominently in their current position. By making such amendment, this would then mean that we could sign the website off as being, as the risk statements contained within the blogs pages would then be sufficiently prominent."
9 . Maybe it might work if the blog is limited to one per page.
10. Anyway we are in agreement that the risk warnings are there to protect the public and help to differentiate regulated advice firms from non - regulated advice firms. We are hoping that we can find a solution that allows us to engage with readers whilst complying with the rules and not losing engagement.
CAN YOU HELP?
| fg-fin-proms-prominence.pdf |
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