Financial Promotions

A promise in an email is still a financial promotion.

"Returns are basically guaranteed." "You can expect double digits this year." An advisor writes it to move a deal, and under the financial promotion rules it has to be fair, clear, and not misleading. VerbaPulse flags that language in Outlook and Gmail before the message leaves.

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The problem

Every client email can be a financial promotion

A communication that invites or induces someone into investment activity is a financial promotion, and the channel does not matter. A one-line email to a prospect counts the same as a glossy brochure. Under the UK regime (FSMA section 21 and the FCA's fair, clear and not misleading standard in COBS 4), under FINRA Rule 2210 in the US, and under the MiFID II marketing rules in the EU, that language has to be balanced.

The problem is who writes it. The advisor or relationship manager is mid-deal, reassuring a nervous client, and the words that move the deal ("guaranteed", "risk-free", "you can't lose") are exactly the words that create a promotions breach. The firm usually finds out the same way every time: after it sends, in a supervision sample, days later, when the email has already been in the client's inbox.

What it catches

The phrases that turn a pitch into a promise

VerbaPulse reads the draft as it takes shape and flags the span that creates the exposure, with a plain reason and a balanced rewrite that keeps the writer's intent. Real output from the product:

VerbaPulse Critical

"I can guarantee you'll beat your current returns, completely risk-free."

Guarantee and risk-free claim

we aim to improve your returnsReplace

we strive for strong returnsReplace

Phrase-level, in the writer's voice. The selling point survives, the unqualified promise does not.

The same check covers the softer phrasings that a keyword filter misses:

Conditional and hypothetical guarantees aimed at the client ("basically guaranteed", "you really cannot lose").
Unbalanced return promises and projections ("you can expect 12% this year", "we will definitely hit target").
Written-commitment language that turns a projection into a promise ("I would put that in writing").
Risk-free and capital-protection claims that are not actually unconditional.
Past performance presented as a forward promise, without the balancing context the rules expect.
Your own manual: upload your communications policy and VerbaPulse enforces it on every draft as a policy violation with a plain explanation.

How it works

In the inbox your team already uses

Install in minutes

The Outlook add-in deploys org-wide through the Microsoft 365 admin center, and the Chrome extension covers Gmail. No new tab, no change to how advisors write.

Write as usual

As the draft forms, a promotion-risk span is flagged with severity and a plain reason, plus a balanced rewrite that keeps the point the advisor was making.

Fix before it sends

One click applies the compliant wording while it is still a draft. Anonymized events feed an audit trail your compliance team can show a regulator.

Where this fits

A writing-time control, not a promotions sign-off

VerbaPulse does not approve financial promotions and it does not lift your supervision duties. It is the layer that sits earlier than all of that: the moment the advisor is writing, while the wording can still change. This is the front-end shield for email compliance for financial services, and it complements the approval and archiving systems you already run (Smarsh, Global Relay, Proofpoint), so fewer promotions breaches reach them.

Email content is never stored: drafts are analyzed in memory and discarded immediately.
Nothing is used to train AI models.
The audit trail is anonymized by design: risk types, severities, and outcomes, never message text or named individuals.
It tells the difference between making a promise and discussing one, so a compliance reminder about guarantees does not get flagged as a guarantee.

For the evidence behind this, our language risk benchmark runs real, anonymized cases through the product and reports what it flags.

FAQ

Common questions

Does VerbaPulse approve our financial promotions?

No, and you should be wary of any tool that claims to. VerbaPulse is a writing-time control: it flags the language patterns that make a client email a non-compliant promotion (guarantees, risk-free claims, unbalanced return promises) before the message leaves, and suggests compliant wording. Your sign-off, approval workflow, and supervision obligations stay exactly where they are.

Which rules does this relate to?

In the UK, the financial promotion regime under FSMA section 21 and the FCA's fair, clear and not misleading standard (COBS 4). In the US, FINRA Rule 2210 on communications with the public. In the EU, the MiFID II requirement that marketing communications be fair, clear and not misleading. This page describes language risk and is not legal advice.

Does it catch conditional or hypothetical guarantees?

Yes. The risk is rarely the word guaranteed on its own. It is also the softer phrasings aimed at the client: basically guaranteed, you really cannot lose, I would put that in writing, you can expect double digits. VerbaPulse flags those patterns and offers a balanced rewrite.

Does it replace our approval workflow or archiving?

No. Promotion approval, books and records, and archiving platforms still do their job. VerbaPulse adds the layer they do not have: the moment before send, while the wording can still change, so fewer breaches reach the approval queue or the client inbox in the first place.

Is email content stored anywhere?

No. Drafts are analyzed in memory and discarded immediately. They are never stored and never used to train AI models. The audit trail keeps anonymized risk events (type, severity, action taken), never message text and never named individuals.