FSA has clarified its expectations on "white labelling" of insurance and investment product promotions. Although not defined by FSA, "white labelling" includes arrangements where a product or service is offered under the brand of one company while a separate company makes the product or provides the service. In meeting FSA requirements of making financial promotions "fair, clear and not misleading", promotions must make clear to customers with which firm they would be entering a contract. ICOBS and COBS address this requirement in respect of insurance and investment products. The update stresses the promotion as a whole must consistently clarify which firm is discharging which specific function towards the product or service. As part of FSA's ongoing monitoring, it will undertake a white labelling review in Q4 of 2009.