Case studies
We have developed a series of case studies to help firms understand the implications of the COBS rules and principles-based regulation.
Communicating with clients, including financial promotion
Provisions that apply to communicating with clients, including financial promotions, are set out in COBS 4. So, these case studies should be read in conjunction with COBS 4 (see also PERG 8 & 13, and PS 07/5). They are designed to show how our financial promotion rules for investment products and services might operate in practice. They cover some of the questions that we would expect firms to ask themselves in designing promotions. But, it is important to note that the rules must be applied on a case-by-case basis. What is relevant to our discussions here may not be all that firms should consider for a particular promotion. We are not saying that this is the only way in which the high-level rules may be satisfied. We only intend to raise some of the considerations to show how the new requirements could work in practice.
The example promotions included in the case studies are not intended to be copied as examples of good practice. Some examples, such as the promotion in case study 1, may have defects other than those identified.
The first three case studies are centred on a fictitious marketing campaign by MPBR Asset Management, to show how the same rules might apply to different promotions at different stages of a campaign. The fourth case study looks at past performance.
Case studies
Case study 2: Fluency's more detailed promotion
Case Study 3: Fluency's direct offer financial promotion
Case study 1: Fluency's high-level promotion
The appopriateness test
These two case studies illustrate some of the questions and answers. They are intended to reflect real-life scenarios and provide material, including questions, which firms may find useful when considering the issues raised. Inevitably, these issues are not exhaustive.
We have also included examples of good and poor practice. Generally, these are to help firms and their management reach decisions on how to achieve the desired outcomes.
Case studies
Case study 1: Assessing appropriateness
Case study 2: General and personalised communications