UK Finance has long called for a review of the FCA’s financial promotion rules for consumer credit, which have become increasingly outdated and misaligned with modern communication channels and the ways consumers interact with these channels. Many of the requirements now proposed for removal or simplification are already covered effectively by the obligations placed on firms by the Consumer Duty, which provides a robust, outcomes-focused, overarching framework for firms. We therefore view the FCA’s proposals as both proportionate and necessary, particularly in supporting clearer, more effective use of digital and space-constrained channels.

UK Finance welcomes the FCA’s discussion of potential reforms to cost disclosure rules, as an important step towards a future consultation. Members are encouraged by the FCA’s openness to greater flexibility, including around the potential use of alternative cost disclosures where these better support consumer understanding of the cost of credit.

This review and proposed reform are taking place against a backdrop of considerable legislative and regulatory change to consumer credit. Members are keen to see clarity from the FCA on how the CONC 3 proposals interact with these broader developments, and UK Finance will continue to engage closely with both industry and the FCA as this work progresses.