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Eversheds Digital Banking Seminar Eversheds Digital Banking Seminar

Eversheds Digital Banking Seminar - PowerPoint Presentation

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Eversheds Digital Banking Seminar - PPT Presentation

Delivering compliant digital products 30 September 2015 Clare Hughes Partner Advertising retail financial products via digital media The origination process and points to note across different products ID: 547709

media digital financial customer digital media customer financial information promotions clear credit cont

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Presentation Transcript

Slide1

Eversheds Digital Banking Seminar

Delivering compliant digital products

30

September 2015

Clare Hughes

PartnerSlide2

Advertising retail financial products via digital media

The origination process and points to note across different products

The use of apps and the challenges they present

Treating customers fairly – what does this mean in the context of digital media?Retail financial products – our top 10 tips

What we will coverSlide3

The key challenge is often spaceFacebook

, Twitter, banners, in app advertisingBalancing the brevity valued in digital media with the requirement to show information

Taking into account legal requirements and those of the regulator Issues to bear in mindFinancial promotions must be internally compliant

No reliance on click-throughsConsistent message from OFT and FCA

Latest FCA position set out in FG15/4 – Social Media and Customer Communications

Financial promotions and digital mediaSlide4

Is this a brand promotion message or a product specific message?

How does this impact form and content?Are you including trigger information?Do you need to? What impact on space does this have?

Can you avoid including trigger information in that financial promotion?At what stage in the dialogue with the customer are you? Can the trigger be postponed to a later screen?

Can you use phasing in effect to make the financial promotion bigger?BannersPlacement of calls to actionPushing customers through necessary information

Considerations

Financial promotions and digital mediaSlide5

Is this a financial promotion?Credit and the boundaries of mere publication

Presentation of risks as well as benefitsFCA driven requirement

Relevant to mis-selling so important to get this right

How to present itSo called “hover boxes”?How prominently?Small print?Transparency is key

APRsIn relation to credit and mortgages – are you tracking your APRs?Web build and application routes

Considerations

Financial promotions and digital mediaSlide6

Regulatory riskShift in legal and regulatory risk

FCA is more vocal OFT – relevant to credit productsFCA

does review financial promotions and is focussing on customer communications“Smarter Customer Communications” discussion paper

Considerations

Financial promotions and digital mediaSlide7

Credit - collecting customer informationAffordability assessments and verification of data

Requesting evidence from the customer? Benchmarking against standard data?

Phases of contracting – pushing the customer through separate screens vs. tabs and links to documentsProvision of pre-contractual information – all products

“In good time”?FCA’s TR15/5 – Provision of Premium Finance to Retail General Insurance CustomersProblems of not providing pre-contractual information correctly and at the right time

Consumer Credit (Disclosure of Information) RegulationsFinancial Services (Distance Marketing) RegulationsDurable medium?

Problems with getting this wrong

Copies sent tot he customer’s email?

Originating accounts

Digital media Slide8

Provision of pre-contractual information cont.Problems of presentation –

SECCIsSelf standing

FormattingConsequence of getting it wrong – unenforceabilityThe agreement / terms and conditions

Clarity of presentationIs it clear to the customer this is the point of “purchase”?Digital signaturesCredit – on the agreement – formatting of the agreement

Scroll boxesThe specific problem of creditForms of signature

Typing a name

Click boxes

Electronic codes

Capturing your signature (if required)

Storing a record of the agreement for future reference

Originating accounts

Digital mediaSlide9

Mortgages – specific issuesNo issue sending offer docs,

KFIs etc to the customerEven second charges to be free of the challenges of the

CCA soonBUT – the mortgage deed must be signed with a wet signature

Biggest barrier to use of digital mediaAdvice post Mortgage Market Review changesUse of Skype & FaceTime

Originating products

Digital media (cont’d)Slide10

Is there enough space to be able to go through the origination process properly?Presentation of documents

Is it making things too easy?Remember the regulator’s concern in some markets that the application process was presented as ease and “hassle free” leading to poor customer outcomes

Using apps

Digital media (cont’d)Slide11

TransparencyIn financial promotions

In the customer journeyAre you facilitating the customer’s ability to shop around?Are customers given the option to print / store documents?

Is there a clear understanding of the customer’s cancellation rights?Clear provision of a helpline / contact number?

Have you got all the information you need to decide whether the product is appropriate for that customer?What does

TCF mean for digital banking?

Digital media (cont’d)Slide12

Try things for yourself Walk through the journey end to end

Was the experience clear and transparent?Was enough information provided?Structure before detail

Keep the customer at the heart of your decisions around the use of digitalIt isn’t just about ease – it is also about making informed decisionsThe need for standalone compliance

Don’t bury risks and regulatory required informationBe clear, fair and not misleadingDon’t compromise proper execution to move with the trend

Our top tips

Digital media (cont’d)Slide13

Questions?Slide14

Partner

Clare Hughes

Partner, Company commercial+44 783 113 3288

clarehughes@eversheds.comEvershedsOne Wood StreetLondon

EC2V 7WS