Financial Promotions for Private Markets: Same Rules, Higher Bar
The regime isn’t new — expectations are
Financial promotions rules for high-risk investments under COBS4.12 have existed for years. For private equity and venture capital managers, the shift is in application: clearer risk warnings, tighter investor targeting, robust appropriateness testing and stronger evidence you followed the rules across every digital touchpoint.
What “good” looks like in 2025
Investor targeting and gating
Only HNW, sophisticated or professional investors access materials. Build explicit routes for each, with attestations and validations baked in.Appropriateness before access
Short, scored assessments determine whether retail investor can proceed to fund details or the data room.Prominent, contextual risk warnings
Warnings appear before viewing materials, at key decision points and on subscription pages—clearly worded, not buried for retail investors.Evidence and auditability
Capture the full journey: categorisation choices, test scores, timestamps, IPs and acknowledgements. Make retrieval simple.Channel consistency
Apply the same standards to email campaigns, landing pages, PDFs and your investor portal. No weak links.
Practical implementation checklist
Map your investor journeys and identify where gating and warnings must appear.
Create categorisation flows for HNW, sophisticated and professional investors.
Configure a brief appropriateness test with pass/fail logic for applicable investors.
Standardise warning components and placements across all channels.
Turn on event logging: every step should be auditable.
Schedule quarterly reviews and A/B tests to keep journeys clear and compliant.
The FTS approach
FTS provides a white-label portal with:
Built-in investor categorisation flows.
Configurable appropriateness tests and pass gates.
Persistent, reusable risk-warning components.
End-to-end audit logs and exportable evidence packs.
Takeaway: The rules haven’t arrived yesterday—but the bar for execution has moved. Treat promotions as a design system, not a disclaimer.