In light of the current OFT scrutiny of affiliate networks, affiliates and advertisers and our eagerness to ensure compliance with all UK legislation, we kindly ask that all publishers and advertisers take positive steps to ensure the following:
- Where affiliates and/or advertisers introduce consumers to lenders or other credit brokers that they hold a Consumer Credit Licence which covers that activity;
- Where affiliates and/or advertisers act as credit intermediaries, clarity concerning the extent to which that credit intermediary acts independently or for others, and how that is disclosed to consumers;
- That marketing material :-
- is clear and unambiguous;
- clearly identifies the commercial intent (unless already apparent from the context);
- does not imply directly or indirectly that the affiliate/advertiser is a consumer;
- where applicable informs consumers that the affiliate business receives remuneration from the merchant business/advertiser;
- containing editorial content that has been paid for, makes it clear that this is the case.
These steps are in addition to a requirement to comply with all legislation regarding data protection, electronic communications and consumer credit.