The Financial Services Consumer Panel has published a discussion paper on digital advertising in financial services. It is deeply concerned about the use of “adtech” to create detailed profiles of individual consumers, as it says this creates an environment for discrimination, manipulation and exploitation as well as the perceived benefits of being able to create personalised and targeted marketing. Its particular concerns are:
- the number of google searches for high-cost credit keywords, and how firms target customers, together with customers being drawn to unauthorised firms, and misleading application processes: to combat this, the Panel would, among other things, like to see FCA introduce a requirement that the way in which promotions target consumers should be approved by an authorised firm and to consider the need for stronger risk warnings; and
- the number of unregulated firms operating in the pensions-to-cash market, and poor disclosure of regulatory information and risk warnings: FCA should, among other things review disclosures and investigate the digital marketing practices of brokers who target under 55s and the firms that pay them for marketing leads