Factors for firms to consider when preparing financial promotions and communications

In communicating information, firms should:

  • consider whether the omission of any relevant facts will result in the customer being given information which is not clear, fair and not misleading; 
  • consider whether any comparison of products or services (whether or not provided by the firm) is fair and balanced;
  • provide general disclosures on any commission arrangements associated with the promotion (see chapter on financial incentives here)
  • use plain and intelligible language;
  • ensure the promotion or communication is easily legible (or for information given orally, clearly audible);
  • specify the name of the firm making the communication or the firm on whose behalf it is being made;
  • show the name of the lender (where it is known) if the communication or promotion relates to credit broking in a prominent way.

Financial communications must not:

  • state or imply that the firm is a lender if it is not;
  • suggest or state that credit is available regardless of the customer's financial circumstances or credit status;
  • mislead the customer as to the availability of a particular credit product;
  • conceal or misrepresent the identity or name of the firm;
  • use false testimonials, endorsements or case studies; or
  • use false or unsubstantiated claims as to the firm's size, experience or pre-eminence.

Credit brokers – including motor dealers – must indicate, in their financial promotions and communications:

  • the extent and limitations of their powers and in particular whether they work exclusively with one or more lenders, or work independently; and     
  • the existence of any financial arrangements with a lender which might impact on their impartiality in promoting a credit product to a customer.