HMT Regulatory Framework of Financial Promotions Approval - Which? response

We are pleased that HM Treasury has launched this consultation as we think it is a positive step in tackling consumer harm resulting from misleading, inaccurate and inappropriate financial promotions. While we note that these proposals are not designed to address fraudulent activity, we consider that such legislative reform would help consumers who suffer a financial loss as a result of financial promotions from unauthorised firms. 

Consumers are not likely to be aware of the regulatory perimeter therefore - from their perspective - an advertisement on an online platform will appear the same, whether it is classed as a financial promotion or not. It is unclear how many consumers suffer financially specifically as a result of a financial promotion from an unauthorised person which has been approved by an authorised firm. We therefore consider it helpful to consider this consultation, and HM Treasury’s focus more generally, in the wider context of online and financial scams.