Digital Marketing Manager at The Childrens Mutual
31 March 2008 12:16pm
Hi, I'm in a bit of tricky position, I wish to disengage from a pay-per-lead model with which we pay our affiiates and offer them a PPA model, with further payments available if a customer sets up a direct debit. This should cut out fraud and hopefully give our top affilates the nudge to push upsells more at source. However, my rather rudimentary understanding of FSA regs and recommendations leads me to believe that I need to inform the customer of payments made to third parties during the process and before they click "buy".
I've done some scouting around and have seen that some banks and insurance services offer transparent incentives to affiliates on a per sale basis but nowhere have I seen a sliding scale implemented and I'm not aware if the customer needs to be informed of these payments anyway. Can anyone advise please?
31 March 2008 12:23pm
We've come across this a lot in the past having worked in the financial sector. You do need to get this checked out by the FSA, but in the past we have adhered to these hard and fast rules.
If you're receiving a fee, ie a Proc fee for example, then it muct be declared because you are selling other companies products and services, and therefore need to show you're independant, or guided in such a way, all pary of being open, honest and upfront with customers.
However, we've not found this to be the case with bounty's on a PPL basis (obviously). With PPA, this does vary, but remember. it's someopne else selling your products / sertvices, so they have to declare the commission fee you are paying them.
The reason I say it's worth checking it out with the FSA is because it should be right and proper that you ease the honest and open approach along the way, so they may say it's down to you to make sure your re-sellers are acting in the proper way.
Hope that helps, like all these things it's a bit of a minefield, but that's what the FSA are for I guess.
31 March 2008 12:31pm
Thanks a lot for that, It seems that I'll have to approach the FSA then!
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