Market Conduct, Fair Disclosure & Client Communications
This guidance sets out expectations for how licensed entities communicate with clients and the public, including advertising standards, disclosures, and ongoing communications.
Purpose of This Guidance
Clear and fair communication is central to market integrity. This guidance explains the standards that apply to marketing, disclosures, and ongoing communications with clients and counterparties.
General Conduct Principles
Communications must be fair, clear, and not misleading. Information should be presented in a manner that enables informed decision-making.
Advertising and Promotional Material
- Marketing must accurately reflect authorised activities
- Risk disclosures must be prominent and not obscured
- Past performance must not be presented as indicative of future results
- Comparative claims must be capable of substantiation
Risk Disclosures
Risk disclosures should be clear, balanced, and tailored to the nature of the service. Boilerplate or generic disclosures may be insufficient where risks are material.
Ongoing Client Communications
Licensees should maintain appropriate channels for ongoing communication, including notifications of material changes affecting services or terms.
Recordkeeping
Records of client communications and marketing material should be retained to support supervisory review and dispute resolution where required.
Conclusion
Responsible communication supports trust and long-term market confidence. Licensees should view market conduct as a governance obligation, not a marketing constraint.