On 1 July 2020, the Financial Services Consumer Panel (FSCP) issued a discussion paper on digital advertising in financial services. The discussion paper sets out potential consumer protection issues highlighted in two earlier FSCP exploratory research studies covering the digital customer journey for high-cost consumer lending and pensions encashment and online marketing strategies used by high-cost lenders and cash-to-pensions firms.

The FSCP research provided evidence of potential consumer protection issues in the digital advertising of financial services that might require further regulatory attention – including more concerted cross-regulatory effort.  Whilst some of the activities may not contravene current FCA rules the evidence calls into question whether firms are acting in the best interests of their customers including potentially vulnerable customers.