How to run a financial-promotion review you can defend.

A cash deposit, an investment, consumer credit, a pension and a cryptoasset are governed by different rules. Applying investment risk-warning rules to an FSCS savings ad is a false positive; missing them on a high-risk investment is a real breach. Pin the product type before anything else.

With PromoCheck: PromoCheck classifies the product type and applies only the rules that apply, so a compliant deposit passes cleanly.

For every claim in the promotion, ask which Handbook provision it engages: COBS 4.2.1R (fair, clear, not misleading), 4.5.2R (balance), 4.6.2R (past performance), 4.12A (high-risk), FSMA s21 (approval), FG24/1 (social/standalone). A finding without a rule behind it is an opinion, not a review.

With PromoCheck: Every PromoCheck finding names a specific rule and its Handbook reference, nothing is raised without one.

Where the issue is something present in the copy, record the verbatim words that create it, not a paraphrase — the defensible answer to 'why did you flag/allow this?' is the exact phrase and the exact rule. Where the issue is something absent (a missing warning, say), there's no phrase to quote — say plainly that it's your judgement the required element isn't there, not a paraphrase of text that doesn't exist.

With PromoCheck: Findings that cite present text quote it verbatim from the promotion, code-checked; a quote that can't be verified is dropped in code. Findings that something is missing carry no quote by definition and are marked as an omission, not presented as verbatim-checked.

If a piece is too thin or ambiguous to assess, record that, and what you'd need to assess it, rather than forcing a judgement. A confident wrong answer is worse than an honest 'insufficient information'.

With PromoCheck: PromoCheck returns INSUFFICIENT_GROUNDING and lists what it would need, instead of guessing.

COBS 4.11 expects an adequate record of each promotion and the basis for the decision. Capture which rules were applied, the outcome, and the version of your rulebook at the time, rules change, and you must be able to show what applied when.

With PromoCheck: Every review is recorded with the versioned rule set applied, timestamped, in an exportable evidence pack.

Where a judgement is genuinely borderline, it should be escalated and decided by a named, competent person, not auto-cleared. Document who decided and why.

With PromoCheck: High-assurance mode runs two independent models; any disagreement is escalated for human review, never auto-cleared.

Under SM&CR a named senior person is accountable, and you must be able to evidence that your controls operated effectively. That means a durable, verifiable record, one that can be shown to be unaltered, not a spreadsheet anyone can edit after the fact.

With PromoCheck: The audit trail is hash-chained and signed; any later change fails verification, and the whole trail exports for a regulator request.