Clive Gordon has spoken on FSA's high-level priorities in relation to financial promotion, with specific reference to digital media. His key points included:

  • each promotion must be compliant in itself – FSA does not accept a click-through link to required disclosures. Neither does it accept a rollover to them;
  • all communications must be clear, fair and not misleading;
  • depending on the media chosen, it may be inappropriate to market certain products – for example, Twitter would not allow the necessary word count or restrictions for marketing complex products; and
  • firms must consider the shelf life of promotions in various media.

He concluded by saying FSA does not wish to stop firms using digital media, but wants them to ensure they have proper systems and controls when they do so. Finally, he referred to the Financial Conduct Authority's (FCA) powers to ban misleading promotions. (Source: FSA Speaks on Financial Promotions)