Terms of use
1. What this service is
FinProm Check is a pre-publication check on promotional copy, provided by Paradigm Consulting to firms it supports. You paste in copy you intend to publish, or upload the image, and the service returns an assessment against the FCA's financial promotions rules, including COBS 4, MCOB 3A, ICOBS 2, the Consumer Duty in PRIN 2A and the section 21 FSMA regime, along with suggested wording where it finds a problem.
2. What it is not
It is not approval of a financial promotion, and it is not a section 21 approval. Nothing the service returns is sign-off. Responsibility for every promotion your firm publishes stays with your firm and with the individual your firm has made responsible for approving promotions. A green rating is not permission to publish. Your approver should reach their own view, and where they and an assessment disagree, your approver decides.
It is also not advice on a specific set of facts. If you need that, speak to your Paradigm consultant or the Paradigm Consulting helpdesk.
3. Who stands behind the assessment
The reference material the service works from is Paradigm Consulting's own, including our reading of FG24/1 and FG24/3 and our sample wordings. Paradigm Consulting provides the assessment as guidance, on the same footing as guidance from the Paradigm Consulting helpdesk, and it reflects our view of the rules as they stand on the day it is produced.
It does not bind the FCA, and it is not a guarantee that the FCA, a lender, a provider or anybody else will agree.
4. It uses AI, and what that means for you
Assessments are produced using a large language model supplied by Anthropic. Two consequences are worth stating plainly rather than burying.
It can be wrong in both directions. It can raise something that is perfectly fine, and it can miss something that is not. Treat the output as a prompt to think rather than as a verdict.
The copy you submit leaves Paradigm. What you paste in, including any image you upload, is sent to Anthropic to be processed, under Paradigm's commercial agreement with Anthropic, which does not permit that content to be used to train models.
5. What you may submit
Copy your firm intends to publish, or has published. Please do not submit personal data about clients, and do not submit material that is confidential to somebody else, such as lender or provider documents you are not free to share. The service does not need any of it in order to assess a promotion, and everything submitted is retained.
6. What we keep, and who can see it
Each submission, its assessment and any image you upload are stored in Paradigm's systems as the record of the check.
Everybody at your firm with access to the service can see everything your firm has submitted, whoever submitted it, on the basis that a promotion belongs to the firm rather than to the person who pasted it in. Paradigm staff can see submissions across all firms. Firms cannot see each other's submissions.
Where Paradigm holds an approver's email address for your firm, or you supply one with a submission, the assessment can be emailed to that address.
7. Access and fair use
Access is granted to a named person and confirmed by Paradigm against the firm you act for. Please do not share your sign-in, and tell us promptly when somebody leaves your firm.
There is a limit on the number of checks a firm may run in any 24 hours. It is set well above normal use and exists to keep the cost of the service predictable.
Paradigm may suspend or withdraw access, for a person or for a firm. In practice that follows a firm ending its membership, somebody leaving, or misuse.
8. Availability
The service is provided as it stands, without a service level commitment. It may be unavailable for maintenance, or because something it depends on is unavailable.
9. Changes to these terms
We may revise these terms. Where a change is material you will be asked to accept the revised version the next time you sign in. The version and date at the top of this page identify what you accepted.
10. Questions
Speak to your Paradigm consultant, or contact Paradigm Consulting through paradigm.co.uk/compliance.