Compliance Policy

Last updated: {{DATE}}
Publisher: Tenfeet Ltd,Compliance & Use of Content

Last updated: {{DATE}}
Publisher: Tenfeet Ltd (“we”, “us”, “our”) — provider of advisor-ready templates and a curated newswire for regulated financial advisory firms.

This page explains what we provide, what you must still do, and how to use our materials responsibly under UK and US rules. It applies to all content we supply, including the Advisor Newswire and Niche Profile templates (“Materials”).

Important: It’s your publication. You remain the publisher, approver, and record-keeper for anything you send to clients or prospects. We do not provide investment, legal, tax, or compliance advice.

1) Scope: What We Provide

Educational, template-based content for client/prospect communications:
- Advisor Newswire: short, client-friendly blurbs (100–140 words) with sections: What happened • Why it matters • What to consider, plus suggested subject lines and CTAs.
- Niche Profiles: audience-specific copy blocks (landing page sections, email sequences, ad text) and a phrasing bank designed to avoid common compliance pitfalls.
Compliance-aware scaffolding: risk/limitations language, outcome-neutral phrasing, and a one-page Evidence Sheet (version/date, target market, risk notes).
Localization prompts: where UK vs US language may diverge (e.g., ISA vs Roth; Consumer Duty vs SEC Marketing Rule).

What we do not provide

Compliance approval, legal sign-off, or regulatory filings.
Personalized suitability/financial promotions assessments.
Performance claims, forecasts, or recommendations to buy/sell any investment.
Operation of your ESP/CRM or record-keeping on your behalf.

2) Your Responsibilities (UK & US)

You agree to:

Act as the publisher. You are the “firm” responsible for all communications you send or publish.
Approve content internally (or via your appointed approver) before use.
Localize and verify all facts, figures, dates, and regulatory wording for your jurisdiction and audience.
Maintain records (books & records) of promotions and approvals, including versions, dates, approver, and where/when the communication was used.
Avoid personal advice unless the communication is targeted and compliant with your permissions and engagement terms.
Add your own firm disclosures (regulator details, ADV/CRS or FRN, privacy links, conflicts where relevant).
Monitor timeliness. News items become stale; update or remove as needed.
Ensure fair, clear, and not misleading presentation (UK FCA), or truthful and not misleading (US SEC), with balanced risk language and no unsubstantiated claims.

3) Best-Practice Workflow (checklist)

Before publishing:

☐ Insert firm name, regulator details, contact links.
☐ Choose the correct region track (UK or US) and swap local terms (ISA vs Roth; NI vs Medicare, etc.).
☐ Verify any time-sensitive facts (rates, thresholds, dates).
☐ Add risk/limitations note and remove any inadvertent performance language.
☐ Complete the Evidence Sheet (below) and save a PDF of the final version.
☐ Obtain approval from your designated approver/CCO.

After publishing:

☐ Archive the final copy/PDF, screenshots, send lists, and approval record.
☐ Log channels used (email, blog, LinkedIn, ads), dates, and audience segment.
☐ For testimonials/endorsements (if used), store disclosures/consents.

4) Evidence Sheet (template fields to keep on file)

Asset name & channel (e.g., “Newsletter #12, Sep 2025”)
Version & date (e.g., v1.1 • 30 Sep 2025)
Target market & intended outcome (informational; not advice)
Key risks/limitations disclosed (no guarantees, may become outdated)
Localization (UK/US) & sources checked (internal log)
Approver name/initials & date
Storage path / link to archived copy & send report

5) Language Standards (what to use / avoid)

Use

Educational framing (“in general,” “may,” “can,” “depends on your circumstances”).
Balanced statements (benefits and limitations).
Outcome-neutral phrasing (“de-risk concentration,” “map cash/tax dates”).
Plain English, short sentences, no market calls.

Avoid

Predictions/guarantees (“will outperform,” “ensure,” “safe income”).
Selective or cherry-picked performance references.
Implying regulator approval or endorsement.
Urgency gimmicks that pressure clients (unless justified and fair, e.g., tax-year deadlines with context).

6) UK Notes (FCA / Consumer Duty)

Financial promotions must be fair, clear and not misleading and show fair value to the target market.
Avoid past-performance implications; include material risks and limitations.
Keep records of promotions and approvals.
Ensure Consumer Duty outcomes are considered (foreseeable harm, information needs, consumer support).
For testimonials or case studies, ensure they are representative, disclose any incentives, and avoid implying guaranteed outcomes.

Add your FCA FRN and firm details where indicated. Consider compliance pre-approval if your structure requires it.

7) US Notes (SEC Marketing Rule)

Do not make untrue statements of material fact or unsubstantiated claims.
Testimonials/endorsements and third-party ratings are permitted with required disclosures (compensation, conflicts, criteria).
Keep books and records of advertisements, including versions and distribution.
Ensure performance content (if any) follows rule conditions; our Materials do not include performance by design.
Provide links to Form ADV/CRS and privacy disclosures as appropriate.

8) Newswire: Specific Responsibilities

Timeliness: Verify events and dates at the time you send. If a fact changes, update or omit.
Context & suitability: The Newswire is general information. Do not imply that a market move requires client action.
Balance: Pair “Why it matters” with “What to consider” that is generic (e.g., review cash rate, runway). Avoid prescriptive trading language.
Attribution: If you add third-party quotes or data, cite appropriately and respect copyright.

Suggested footer line (pick region):

UK: “Educational content. Not personal advice. Investments can go down as well as up. {{Firm Name}} is authorised and regulated by the FCA.”
US: “Educational information only, not an offer to buy/sell any security. Past performance is not indicative of future results. See disclosures: {{link}}.”

9) Profiles (Templates): Specific Responsibilities

Personalization: Replace tokens (firm name, services, fees, booking link) and confirm accuracy.
Claims: Keep benefits outcome-neutral (e.g., “clarity,” “cadence,” “guardrails”). Avoid “save tax” or “beat the market.”
Target market: Use the Profile only for the audience it was written for (e.g., Tech Professionals).
Ads: For paid ads, ensure platform policies and regulator rules are followed (character limits can truncate risk text—link to a compliant landing page).
Testimonials: If you insert testimonials, add required disclosures (compensation, representativeness, limitations).

10) Prohibited/High-Risk Content (do not add)

Forecasts (“rates will fall next quarter”), specific buy/sell recommendations, back-tested or hypothetical performance without rule-compliant presentation, unverified claims/statistics, or statements implying FCA/SEC approval.

11) Record-Keeping & Archiving (simple structure)

Store each asset here (example):
/Marketing/{{Campaign}}/{{YYYY}}-{{MM}}/{{Channel}}/Approved/
Include: final PDF/HTML, screenshots, audience list or link to ESP report, Evidence Sheet, and approver sign-off. Retain per your regulator’s period (typically 3–7 years).

12) Third-Party & AI Use

If you augment content with AI or third-party sources, you must verify accuracy, remove confidential information, and ensure you have rights to use any excerpts, images, or data.

13) Data & Privacy

Our templates are designed to avoid client PII. If you insert PII, ensure your usage complies with UK GDPR/DP Act or US privacy laws (state-specific) and your own privacy notice. Link your Privacy Policy in footers.

14) Questions & Approvals

For compliance questions, contact your CCO/compliance consultant. For clarifications about our Materials, email support@tenfeet.co. We can clarify wording, but final approval is always yours.

15) Legal Notes & Disclaimers

Our Materials are provided “as is” without warranties; outcomes are not guaranteed.
Using our Materials does not make us your advisor, agent, or compliance approver.
By using our Materials you agree to our Terms & Conditions and Licence (see Terms page).

Quick “Compliant Send” Footer Snippets (copy-paste)

UK (newsletter/email/blog)

Educational content only; not personal advice. Investments can go down as well as up. {{Firm Name}} (FRN {{FRN}}) is authorised and regulated by the Financial Conduct Authority. Privacy & disclosures: {{link}}. Version {{v}} • {{date}}.

US (newsletter/email/blog)

Educational information only; not an offer to buy or sell any security. Past performance is not indicative of future results. See Form CRS/ADV & disclosures: {{link}}. Version {{v}} • {{date}}.