Financial promotion review

An agent produced a decision record. Every citation in it was checked against the live FCA Handbook by three deterministic checks. No language model was used in any check.

rulebook COBS 4 242 provisions source api.handbook.fca.org.uk review date 2026-08-07

UNGROUNDED: the model cites COBS 4 from memory

agent verdict reject11 findings8 distinct citations7 clean1 rejected0 unverified

The promotion under review

L1THE HELIOS GROWTH BOND -- Your money, working harder.
L2Earn a guaranteed 9.2% per year, every year, for five years.
L3Over 4,000 UK savers have already moved their ISA across.
L4Beat inflation without the rollercoaster of the stock market.
L5Your capital is deployed into a diversified portfolio of UK renewable
L6energy projects with contracted government-backed revenues.
L7Apply before 31 August and we will waive the arrangement fee.
L8Helios Capital Partners. Authorised and regulated in the UK.

The decision record, checked

COBS 4.2.1RL2breachRules

fair_clear_not_misleading_guarantee_claim

COBS 4.2.1 · COBS 4.2 Fair, clear and not misleading communications · effective 2018-10-01 · FCA Handbook(1) A firm must ensure that a communication or a financial promotion is fair, clear and not misleading. (2) This rule applies in relation to: (a) a communication by the firm to a customer in relation to designated investment business which is not MiFID, equivalent third country or optional exemption business , other than a third party prospectus ; (aa) a communication to an eligible counterparty that is in relation to: (i) MiFID or equivalent third country business other than a third party prospectus ; or (ii) insurance distribution ; (ab) a communication by the firm to a customer in relation …
COBS 4.5.2R(2)L4breachRules

benefits_balanced_by_prominent_risk_indication

COBS 4.5.2 · COBS 4.5 Communicating with retail clients (non-MiFID provisions) · effective 2023-02-01 · FCA HandbookA firm must ensure that information: (1) includes the name of the firm (and also, where relevant, the name of the firm that has confirmed the compliance of the financial promotion for the purposes of COBS 4.10.9AR(3)(a) ); (1A) where relevant, includes the date on which the financial promotion was approved ; (2) is accurate and always gives a fair and prominent indication of any relevant risks when referencing any potential benefits of relevant business or a relevant investment ; (3) is sufficient for, and presented in a way that is likely to be understood by, the average member of the group t…
COBS 4.2.1RL4breachRules

capital_at_risk_not_disguised_as_riskless

COBS 4.2.1 · COBS 4.2 Fair, clear and not misleading communications · effective 2018-10-01 · FCA Handbook(1) A firm must ensure that a communication or a financial promotion is fair, clear and not misleading. (2) This rule applies in relation to: (a) a communication by the firm to a customer in relation to designated investment business which is not MiFID, equivalent third country or optional exemption business , other than a third party prospectus ; (aa) a communication to an eligible counterparty that is in relation to: (i) MiFID or equivalent third country business other than a third party prospectus ; or (ii) insurance distribution ; (ab) a communication by the firm to a customer in relation …
COBS 4.2.1RL6breachRules

government_backing_claim_not_misleading

COBS 4.2.1 · COBS 4.2 Fair, clear and not misleading communications · effective 2018-10-01 · FCA Handbook(1) A firm must ensure that a communication or a financial promotion is fair, clear and not misleading. (2) This rule applies in relation to: (a) a communication by the firm to a customer in relation to designated investment business which is not MiFID, equivalent third country or optional exemption business , other than a third party prospectus ; (aa) a communication to an eligible counterparty that is in relation to: (i) MiFID or equivalent third country business other than a third party prospectus ; or (ii) insurance distribution ; (ab) a communication by the firm to a customer in relation …
COBS 4.2.1RL3breachRules

isa_eligibility_representation_not_misleading

COBS 4.2.1 · COBS 4.2 Fair, clear and not misleading communications · effective 2018-10-01 · FCA Handbook(1) A firm must ensure that a communication or a financial promotion is fair, clear and not misleading. (2) This rule applies in relation to: (a) a communication by the firm to a customer in relation to designated investment business which is not MiFID, equivalent third country or optional exemption business , other than a third party prospectus ; (aa) a communication to an eligible counterparty that is in relation to: (i) MiFID or equivalent third country business other than a third party prospectus ; or (ii) insurance distribution ; (ab) a communication by the firm to a customer in relation …
COBS 4.12A.20RL8breachRules

prescribed_rmmi_risk_warning_present

COBS 4.12A.20 · COBS 4.12A Promotion of restricted mass market investments · effective 2023-07-03 · FCA Handbook(1) Subject to (1A) below, the second condition is that before communicating the direct offer financial promotion , the firm , or other person communicating the direct offer financial promotion : (a) obtains the retail client's full name; and (b) having obtained the retail client’s name, communicates to that retail client the following personalised risk warning: [Client name], this is a high-risk investment. How would you feel if you lost the money you’re about to invest? Take 2 mins to learn more. (1A) Where the direct offer financial promotion relates to a unit in a long-term asset fund , th…
COBS 4.12A.6RL7breachrejectedGuidance

no_monetary_incentive_to_invest

COBS 4.12A.6 · COBS 4.12A Promotion of restricted mass market investments · effective 2023-02-01 · FCA HandbookThe requirements in this section relating to the provision of risk warnings are in addition, and without prejudice, to firms ’ other obligations in relation to the provision of information.

COBS 4.12A.6R cited as rules, the FCA publishes COBS 4.12A.6 as guidance

COBS 4.7.1RL7breachRules

direct_offer_contains_information_for_informed_assessment

COBS 4.7.1 · COBS 4.7 Direct offer financial promotions · effective 2025-10-23 · FCA Handbook(1) Subject to (3), a firm must ensure that a direct offer financial promotion that is addressed to, or disseminated in such a way that it is likely to be received by, a retail client contains: (a) the information referred to in the rules on information disclosure ( COBS 6.1.4 R , COBS 6.1.6 R , COBS 6.1.7 R , COBS 6.1.9 R , COBS 14.3.2 R , COBS 14.3.3 R , COBS 14.3.4 R and COBS 14.3.5 R ) as is relevant to that offer or invitation; and (b) additional appropriate information about the relevant business and relevant investments so that the client is reasonably able to understand the nature and …
COBS 4.6.2RL2breachRules

past_or_projected_performance_supported_and_caveated

COBS 4.6.2 · COBS 4.6 Past, simulated past and future performance (non-MiFID provisions) · effective 2021-01-01 · FCA HandbookA firm must ensure that information that contains an indication of past performance of relevant business , a relevant investment or a financial index, satisfies the following conditions: (1) that indication is not the most prominent feature of the communication; (2) the information includes appropriate performance information which covers the preceding five years, or the whole period for which the investment has been offered, the financial index has been established, or the service has been provided (where less than five years, or such longer period as the firm may decide), and in every case t…
COBS 4.3.1RL8breachRules

regulator_status_clearly_and_accurately_disclosed

COBS 4.3.1 · COBS 4.3 Financial promotions to be identifiable as such · effective 2026-01-19 · FCA Handbook(1) A firm must ensure that a financial promotion addressed to a client is clearly identifiable as such. [ Note : article 24(3) of MiFID , article 17(2) of the IDD and article 77 of the UCITS Directive ] (2) If a financial promotion relates to a firm's MiFID, equivalent third country or optional exemption business , this rule does not apply to the extent that the financial promotion is a third party prospectus . (3) If a financial promotion relates to a firm's business that is not MiFID or equivalent third country business , this rule applies to communicating or approving the financial promoti…
COBS 4.5.2R(1)L8compliesRules

firm_name_included

COBS 4.5.2 · COBS 4.5 Communicating with retail clients (non-MiFID provisions) · effective 2023-02-01 · FCA HandbookA firm must ensure that information: (1) includes the name of the firm (and also, where relevant, the name of the firm that has confirmed the compliance of the financial promotion for the purposes of COBS 4.10.9AR(3)(a) ); (1A) where relevant, includes the date on which the financial promotion was approved ; (2) is accurate and always gives a fair and prominent indication of any relevant risks when referencing any potential benefits of relevant business or a relevant investment ; (3) is sufficient for, and presented in a way that is likely to be understood by, the average member of the group t…
What is real here. The rulebook, every provision name, type and effective date, and the three checks. The draft promotion is invented and the firm does not exist. Nothing on this page interprets a rule: the checks ask whether a cited provision exists, whether it is the type the agent claimed, and whether it has changed since the review date.

What is not established. The ungrounded-versus-grounded comparison is a single run of a non-deterministic model. Repeated runs have varied widely, and an earlier version of this harness inflated the ungrounded error rate roughly threefold through a bug in its own citation parser. Treat the difference between the two tabs as illustrative, not measured.