How does the FSA regulate real time marketing approaches made to consumers?
Under the mortgage regime (see MCOB 3.7.1R and 3.7.3R) real time qualifying credit promotions can take one of two forms:‘solicited’ or ‘unsolicited’. • Unsolicited: if unsolicited, a firm can’t make the promotion unless the consumer has an established existing customer relationship with the firm, such that the consumer envisages receiving unsolicited qualifying credit promotions. • Solicited: to be considered a solicited real time promotion, the call, visit or other interactive dialogue must take place only where the consumer initiates it, or it is in response to an express request from the consumer. It must also be clear from all the circumstances that during the course of the real time promotion, qualifying credit will be discussed (MCOB 3.7.1R(2)). Our objective with this policy is to reduce the possibility of high-pressure selling through unsolicited calls. MCOB 3.8.2R sets out the form and content of real time qualifying credit promotions (whether solicited or unsolicited).
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