At the beginning of the year, we appealed the Financial Supervision Authority’s decision to fine Tuleva 100,000 euros for shortcomings in our advertising. The court acknowledged deficiencies in the advertisements but concluded that Tuleva’s fault was minor. As a result, the fine was reduced to 17,500 euros.
Pension fund information must be understandable to everyone
During the dispute, the court conducted a thorough analysis of the requirements for pension fund advertisements. The court emphasized in its ruling that pension fund advertisements must be clear and understandable, even for those with limited financial literacy.
The court identified three shortcomings in our posts from July 2023.
First, financial service advertisements must include a call to review the terms and conditions of the service and consult with an expert. Pension fund advertisements must also specify where investors can access the prospectus and key information document. In some of our posts, this information was only visible after clicking the “Learn more” button. The court noted that this could have led some people to make hasty decisions about their pension fund without enough consideration. (1)
Secondly, the court found that some of our advertisements may have been misleading. For example, we used the phrase “The only honest statistics”. While some posts clarified this — highlighting that pension fund comparisons often distort performance figures, whereas Tuleva always presents accurate returns — others lacked this explanation. The court ruled that advertisements without this clarification may not have been clear to all consumers.
Finally, one of our posts included the phrase “Preserve your pension fund’s performance and choose a low-cost index fund”. Our aim was to explain that fees reduce pension fund returns and that lower-cost funds are a better choice for investors. However, the court found that some people might interpret this as a guaranteed return. (2)
Tuleva no longer publishes posts of this nature. Shortly after publishing these posts, we updated our communication guidelines to ensure compliance and make our messages clearer for everyone. We also stopped using external service providers for our advertisements to prevent potential misunderstandings. Today, all our communications are reviewed by multiple team members to ensure clarity and accuracy.
We take the court’s judgement seriously. Our communications must be understandable to everyone because the financial world can be complex, and people’s prior knowledge varies widely. Tuleva’s mission is to make pension saving simple and accessible for everyone. Moving forward, we will make our messages even clearer and more straightforward. We believe that true clarity doesn’t come from small-print warnings but from ensuring that the main message itself is simple and easy to understand.
- I will save for another blog post the discussion on how small-print calls to review fund documents or consult experts actually do not protect people’s interests. After all, we know most fund documents are written for lawyers, and impartial experts are not readily available to most people.
