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It has felt that the regulatory regime for online financial promotions has not been fit for purpose and some have called it the wild west. However, last month Google announced a significant change to its policy on financial services adverts. From 30 August 2021 financial services advertisers will, as part of Google verification, need to demonstrate that they are authorised by the FCA or qualify for one of the exemptions.

Mortgage intermediary firms may be impacted by this if they advertise on Google or accept leads from advertisers or aggregators that have been acquired this way; these firms should read Google’s update to assess whether they will need to apply for Google verification.

Advertisers, such as lead generation firms, to avoid having to become FCA regulated may seek to become an AR or IAR of a mortgage intermediary firm and let them approve their financial promotions. As regulated entities, principal firms should carefully consider any risks with this approach as they are responsible for the actions of the AR/IAR.

Google’s policy update is a step in the right direction and coupled with Treasury’s confirmed plans to proceed with a financial promotions regulatory gateway, shows clear intent to make life more difficult for those that do not have the correct consumer outcomes in mind.

One key missing piece of the puzzle is the inclusion of financial scams in the Online Harms Bill, although we await the government’s consultation on online advertising regulation which has been promised later this year.

Stacy Reeve – AMI

July 2021



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