piggybank-bodyFor firms subject to the Financial Conduct Authority’s (FCA) conduct of business rules, the world of social media marketing can appear one that is littered with banana skins.

However, as many financial institutions have proven, the potential gains of incorporating social media outweigh the risks of falling foul of the FCA’s rules.

The letting down of the guard could be a result of the FCA giving social media its blessing. As it points out in its ‘Social media and customer communications’ guidance consultation from last year, “digital media can allow new and smaller firms to have a presence in the marketplace”, with social media allowing firms to reach a wider audience.

So, while a financial organisation has a good deal more considerations to make than other brands before signing up to social media, the challenges might mean it has less in the way of competition.

Those that have already stepped online have seemingly done so with both feet, however – HSBC, for example, has five different Twitter handles for its UK target audience alone. All five serve different purposes, of course, but it goes to show the vigour of their social media efforts.

FCA guidance

For many more modest firms, though, just getting a single account up and running is a massive upheaval. For those looking for a place to start, let us point you in the direction of the FCA’s official guidance on using social media for financial promotions.

We have taken the time to summarise the 20-page document for you, but it goes without saying that compliance teams should familiarise themselves with all the available information to the point of recital. Well, almost.

Five key take-aways from the guidance:

1. Each post must comply with FCA rules

This is a fairly daunting prospect for financial firms, as they might feel like they will have to pore over every single post to ensure that they won’t have the FCA on the phone at some point down the line. In reality, this is not majorly different for other brands, who, if they are taking social media marketing seriously enough, should be tuning up their posts for maximum impact.

It’d be irresponsible of me to suggest, however, that financial firms do not have extra considerations to bear in mind, given that the FCA says that any form of communication on social media can be considered financial promotion.

The requirement for all communication to be “fair, clear and not misleading” extends to when tweets are used to link through to a website, known as the ‘click-through approach’. Companies can ensure compliance by having adequate systems in place that monitor and supervise every single piece of communication.

2. Employees’ accounts could come under scrutiny

The beauty of social media is that it is welcoming for businesses and individuals alike. But some businesses may use an individual’s account – the managing director, for example – to spread their message in a more personal way.

For employees of financial firms, however, that doesn’t mean you have free rein to post promotional content at will. As the FCA guidelines state, if a representative of a firm uses their personal social media account to send “inviting” content, then this may constitute a financial promotion and it will have to adhere to the same rules that apply to the firm.

Individuals have to be seen to be not acting “in the course of business” to fall outside the FCA’s regulation.

3. Firms are responsible for retweets

The FCA is wise to financial firms sharing or forwarding content that could constitute promotion for the business. It makes sense when you think about it, otherwise all manner of rogue accounts could be set up with the simple intention of being retweeted by the firm in question.

As such, the financial services industry is unlike any other sector in this respect, as elsewhere brands can retweet praise for their products all day, every day – and some do, although it doesn’t make for a very interesting timeline.

Sensibly, however, the FCA has decided that if a consumer shares or forwards content via social media, the company is only responsible for the original communication. In order to help ensure posts do not end up in front of the ‘unintended’ audience, the FCA advises firms to make use of software that can target particular groups very precisely.

4. Social posts should be given the green light

How firms implement sign-off of digital communications is at their discretion, but the FCA is keen to stress that corners should not be cut in the name of urgency.

Here at M2 Bespoke, we have a number of clients in the financial services sector and know full-well the time it can take to get content through compliance. However, financial content is often less time-sensitive than other topics, due to the fact that changes to regulation, albeit regular, cannot be brought in overnight.

This plays into firms’ hands from a social media point of view, as regards to time, meaning they can afford to have an “adequate system” in place to give content the all-clear.

5. Social media content will need to be archived

If a year down the line you decide a change of direction is required, you can’t simply delete all the posts that have gone before that decision because they don’t quite “fit”.

The FCA requires that a firm has the ability to retain and retrieve its social media communications – and all the responses that arise out of the content.

While the FCA does not state exactly how long records should be retained, it’s generally considered good practice to have a three- to five-year retention period for communications with clients and potential clients.

This is not as big a problem as you might think, however, as there are a number of software options available that allow businesses to archive social media content.


In our opinion, the FCA guidelines suggest things could be a lot worse for UK firms in terms of what they can and can’t post on social media. Anyway, it’s not considered the done thing to be overtly promotional on social media, for a financial brand or otherwise. The aim should be to educate and engage the customer, rather than simply sell to them. The FCA rules only make this a requirement, rather than something brands should do.

If you would like some advice on how to implement social media marketing into your business, please get in touch. Our social media team prides itself on getting the right message in front of the right person at the right time – something the FCA says firms must make every effort to do.