Steps the firm should take include:
- Contacting all customers who purchased the investment following the first advertisement, to confirm that they fully understand the investment and the risks involved. Offering those customers the opportunity to withdraw from the investment without loss.
- Identifying and reviewing any other promotions of complex investment products, to confirm that similar problems could not apply to them. The firm’s complaints records could be reviewed for any themes or trends that would indicate such problems, although identification of repetitive complaints, followed by action to deal with them “at source”, should be a part of the company’s normal procedures.
- Reviewing the firm’s approval procedures and processes to prevent misleading advertisements from being issued in the future.
- Taking care to review the target audience for any new advertisement. It may be appropriate to restrict publication of the advertisement to individuals who are known by the firm to have sufficient knowledge and experience to understand the investment and its risks
