How can communications be directed at the average member of the group to whom they are directed or by whom they are likely to be received?
In satisfying COBS 4.5.2R(3) we do not expect firms to perform some sort of arithmetic calculation on the needs of the median consumer. Targeting a specific group and deciding whether the promotion is likely to be understood by the average member of that group need not be a complex process. For instance, only sophisticated clients will cope with more technical language. So a product marketed to a mainstream audience must avoid the use of jargon if it is to be understood. But if a promotion is sent to a specific group of clients, it may be appropriate to address their needs more closely.