Consumer credit - Product development and marketing

We want to help firms understand what they are required to do under our rules and what our expectations are of them. On this page, we cover the products and services you sell and the need for you to minimise the risk of customer harm.

Product development and marketing

Watch the second video in our consumer credit series on the products and services you sell and the need for you to minimise the risk of customer harm.

It is important that the products you sell or the services you provide meet the needs of customers and that you minimise the risk of harm arising from them.

When developing a new product or service or looking to amend an existing product, it is important to identify who your target market is and how the product or service will meet their needs. Understanding this will also help your business to monitor its customer base and ensure that it continues to meet the needs of customers. For some examples please read CONC 2.2.2G(1).

2 of the key areas you may need to consider when thinking about your target market are the vulnerability of your customers and how accessible your products or services are. We have previously covered consumer vulnerability in an Occasional Paper and Our Approach to Consumers document. We have also published an Occasional Paper on Access to Financial Services in the UK which may help you better understand the potential harms to your customers.

There are also risks in relation to the remuneration of staff and of third parties selling your products. These were considered in our Thematic Reviews on staff remuneration and incentives and on the impact of credit broking remuneration models at the point of sale.

Once a product or service has been released to market, we expect firms to monitor it on an ongoing basis to ensure that it is working as expected, that customer needs are being met and that any potential harm to customers is minimised.

You also need to consider how the product or service is marketed and any financial promotions related to it. The rules on financial promotions for consumer credit lenders and brokers are covered in our Handbook.

Financial promotions are not limited to adverts but can include websites, Facebook posts, tweets etc. We have released Finalised Guidance specifically covering on financial promotions on social media.

All financial promotions and communications must be clear, fair and not misleading - regardless of the media type. They must also comply with our detailed rules on content and presentation.

When we find that a financial promotion is misleading we can:

  • ask the firm to change or remove it
  • ask the firm to write to customers who may have been misled
  • warn or fine the firm
  • ban the promotion