AuditSail
FCA19,766 promotions amended or withdrawn · 2024
INDUSTRY · CONSUMER FINANCE & LENDING

Consumer Duty made every "competitive APR" a provable claim.

In 2024, authorised firms amended or withdrew 19,766 financial promotions after FCA intervention. The ad your customer sees often comes from a broker, an affiliate or a comparison site, not the lender. Under Consumer Duty, the outcome is still yours.

  • FCA
  • CONC
  • Consumer Duty
  • ASA
  • CAP
EXAMPLE
Image ad · Affiliate 1Flagged
Affiliate 1 · SponsoredPersonal loans

Borrow £1,000 to £25,000.
Competitive APR.

Rates from2.9%

Check eligibility →
Representative APR: not shown
!
FailHigh

Rate shown without a representative APR.

FCA · CONC 3 · representative APR+1 more finding

LENDING CATEGORIES COVERED

Personal loansMortgagesMotor financeCredit cardsBNPLSub-prime creditBridging financeAsset financeSME lendingGuarantor loans
THE CONSUMER DUTY PROBLEM

Fair value lives in the broker's ad, not the policy doc.

The lender's compliance team reviews internal marketing. It doesn't see the affiliate landing pages, the broker's TikTok creative, or the comparison-site copy. That is often the marketing your customers actually see.

"A firm must ensure that a communication or a financial promotion is clear, fair and not misleading."

FCA HANDBOOK · CONC 3.3.1R
THE LENDING CHAINEXAMPLE
  1. Tier 1 · Lender
  2. Tier 2 · Principal broker
  3. Tier 3 · Appointed Representative
  4. Tier 4 · Comparison site / aggregator
  5. Tier 5 · Lead-gen affiliateFlagged

Five tiers · one audit trail · 1 flagged

COVERAGE

Every ad. Every broker. Every affiliate.

01

CONC 3 + Consumer Duty in one pass

Representative APR, risk warnings, target market - every ad checked against CONC 3 and the included Consumer Duty rule pack before it ships.

02

See every AR & affiliate

The principal lender sees the ads, call scripts and call recordings each AR, broker and affiliate submits, and how each was graded - in one place.

03

Evidence for the annual board assessment

Consumer Duty requires the board to review customer outcomes at least once a year. Each check records the asset, each rule's outcome and who on your team signed it off.

Image ad · Affiliate 1EXAMPLE
  • Representative APR shownFCA · CONC 3HighFail
  • "Competitive APR" backed by evidenceFCA · CONC 3Inconclusive
  • Risk warning shownFCA · CONC 3Pass
  • Suits the target marketConsumer DutyPass
Score70/100 · pass mark 80
Sign-offRejected · Reviewer 1
THE PRESSURE ON CONSUMER LENDING

FCA promotions data · 2024.

19,766Promotions amended or withdrawn after FCA intervention · 2024
+97.5%Increase on 2023, when the figure was 10,008

Source: FCA, Financial promotions data 2024

RELATED INDUSTRIES

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