Advertising and Promotion of Banking Products

The 10 December 2021 was the publication date of a revised Code of Banking Practice issued by the Hong Kong Association of Banks.  There are many amendments to the existing Code to reflect the increasing digitalization of banking business in Hong Kong.

With particular reference to online advertising for banking products and promotional materials the Code now specifies that any authorized institution (bank) should consider the appropriateness of using such channels for promotion of complex products and services which may be difficult to understand.   To assist such understanding of recipient customers the authorized institution is advised to consider incorporation of visual aids such as images, infographics or whatever other good and intelligible means are available to convey the necessary information in a simple and comprehensible form to customers.

A further amendment provides that where an authorized institution collaborates with a third party promoter such as celebrity, influencers or key opinion leaders for promoting the product or services on social media the authorized institution is stated to accept responsibility and is obliged to ensure that the promotional materials published or shared in this way through the third party channels are fair and reasonable and do not contain misleading information.  An additional provision counsels authorized institutions to maintain one or more convenient and appropriate channels for the public to verify the marketing and promotional activity and material as authentic originating from the authorized institution and communicated through such third party intervention.

Authorized institutions are accordingly required to review their fully detailed terms and conditions in order to ensure that they are current and compliant with the new requirements.