Reviews
Part of How to review finance creators and providers with evidence you can trace
Verifying a finance creator before selection, from identity to exit terms
Use this evidence-led checklist to verify identity, permissions, claims, audience fit, contracts, data handling and exit terms before selection.
A finance creators selection checklist should reveal missing evidence before enthusiasm becomes a contract. Use this one for a creator, agency or financial partner serving adults in England. It is a procurement control, not personal financial advice or a promise of compliance.
Create one dated evidence file per candidate. Mark each item pass, hold, not applicable or unknown, and link the record that supports the mark. Do not total the marks into a score: one unresolved permission, false claim or unsafe data route can outweigh many presentational strengths.
Worked example: 12 March 2026, evidence file for [candidate legal name]. Entry 2: FCA authorisation check. Record: legal name [candidate legal name], reference [FRN], status [authorised], permissions [listed], restrictions [none], reviewer initials [XX]. Attached: screenshot and register URL.
What to take away
- Mark each checklist item pass, hold, not applicable or unknown.
- Regulatory status is evidence about defined activities, not an FCA endorsement of the candidate or campaign.
- Brands share responsibility for clear disclosure of incentivised content under the CMA's social media endorsements guidance for brands.
- Select only after every mandatory gate passes.
Identity and authority
Identity and authority checks
- Record legal entity, company number, signatory
- Match first-party terms to Companies House data
- Identify every financial firm and product
- Search exact entity via FCA authorisation check
- Capture reference number, status, permissions
- Confirm who can approve agreement and claims
- Record the exact legal entity, company number, trading names, contract address and signatory. Match first-party terms to Companies House data, specifically the 'Searching the Companies House register' guidance, while recognising the register's own warning that its information is not comprehensive.
- Identify every financial firm and product behind the proposed content. Search the exact entity through the FCA's authorisation-check guidance, titled 'How to check if a firm or individual is authorised', then capture reference number, status, permissions, restrictions and any principal or appointed-representative relationship.
- Confirm who can approve the agreement, the factual claims and the final communication. Regulatory status is evidence about defined activities, not an FCA endorsement of the candidate or campaign.
Brief, audience and evidence
- Describe the intended adult audience in England, distribution channels, exclusions and foreseeable vulnerability. Do not substitute follower location or age estimates for documented audience controls.
- List each factual, comparative and forward-looking claim. Attach a source with matching product, period, population and geography; label assumptions and scenarios separately.
- Decide whether any wording or link is a financial promotion. FCA social-media guidance, FG24/1, is UK-wide and must be applied to the full communication, including image, caption, destination and platform constraints.
- Define prohibited claims, required risk context and a route for rapid correction or withdrawal. Hold a claim whose evidence cannot be reproduced.
Commercial relationship
- Write down fees, gifts, affiliate arrangements, revenue share, expenses and any interest in the product. Record how the disclosure will remain clear in each format.
- Allocate editorial control, substantiation, approval, comment moderation, complaints and record retention. The CMA's brand guidance on endorsements, 'Social media endorsements: guidance for brands', says brands share responsibility for clear disclosure of incentivised content.
- Set usage rights by asset, territory, channel and term. Cover edits, paid amplification, synthetic versions, creator likeness and post-contract use rather than granting a vague perpetual licence.
Sample disclosure wording for a paid partnership: 'This post is a paid partnership with [brand]. I receive payment for this content. This is not financial advice.'
Sample disclosure wording for an affiliate arrangement: 'I may earn a commission if you use this link. This does not change what you pay. [Add the required risk warning if the product carries risk.]'
Data and delivery
- Map every transfer involving leads, tracking identifiers, audience lists or case-study participants. Specify purpose, minimum fields, lawful basis, retention, deletion and security owner.
- If a processor is involved, check the contract against the ICO's controller-processor terms, 'What needs to be included in the contract'. A template clause does not establish that the operational data flow is lawful.
- Request a small trial deliverable with invented or safely controlled data. Test briefing, evidence capture, approval, accessible disclosure, correction and withdrawal; do not test a live financial outcome on readers.
Decision and exit
- Log unresolved items, owners and deadlines. Ask the financial, legal, privacy or statistical reviewer to examine only the relevant live questions, with the full evidence pack.
- Define termination, removal timing, data return or deletion, asset handover, unpaid commitments and post-exit disclosures.
- Recheck company identity, FCA record, claims, links and disclosures immediately before publication.
Select only after every mandatory gate passes. If the candidate pressures the team to skip an evidence or approval step, record the refusal and hold the work rather than converting uncertainty into a favourable review. In the dated evidence file, note the date, the person who asked, the step at risk, who refused, and attach the message.
Before you act
- Create one dated evidence file per candidate and link supporting records.
- Record the exact legal entity, company number, signatory and contract address.
- Search each financial firm through the FCA authorisation-check guidance.
- Attach sources to every factual, comparative and forward-looking claim.
- Set usage rights by asset, territory, channel and term.
- Recheck identity, FCA record, claims, links and disclosures before publication.
Common questions
What should I do if a candidate pressures the team to skip an evidence or approval step?
Record the refusal in the dated evidence file, noting the date and the person who asked.
How should I test a candidate before committing to a full contract?
Request a small trial deliverable using invented or safely controlled data. Test briefing, evidence capture, approval, accessible disclosure, correction and withdrawal. Do not test a live financial outcome on readers.
What must the commercial agreement cover beyond fees?
Write down fees, gifts, affiliate arrangements, revenue share, expenses and any interest in the product. Allocate editorial control, substantiation, approval, comment moderation, complaints and record retention. Set usage rights by asset, territory, channel and term, covering edits, paid amplification and synthetic versions.
