12 White labelling / co-branding A white-labelled solution is a product / service produced by one firm (Firm A) that another firm (Firm B) rebrands to make it appear as if it has created it. From a marketing perspective, the solution appears to clients as belonging to Firm B’s brand. Co-branding is where the brands / logos / names of both Firm A and Firm B appear on a particular solution. With either a white labelled or co-branded proposition, the consumer must understand who is actually providing the service. How the consumer will understand the arrangement must be considered under the Consumer Understanding outcome. It’s also very important that firms are clear about their roles and responsibilities. To act as a discretionary manager or a platform service provider requires specific FCA permissions which typically an adviser firm may not have. The adviser firm should not hold itself out as being able to undertake an activity for which it does not have the requisite permissions. If the marketing / branding is such that the consumer believes the adviser firm is in some way ‘manufacturing’ the product/service, this will be a relevant factor to consider from a comanufacturing perspective. If an adviser firm has no material influence over the proposition, it may want to think carefully about the branding of the proposition and holding itself out as being the manufacturer of the solution, particularly if things go wrong. It may have no ability to mitigate consumer harms, for example. The positioning of the arrangement also needs to be considered under the clear, fair and not misleading requirement.
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