Is a market commentary a financial promotion?

Usually, yes. If it is likely to encourage a client to invest, or to stay invested, it is an invitation or inducement and COBS 4 applies to it — which is why the fair, clear and not misleading rule and the past-performance requirements are worth reading before you publish rather than after.

Can I put my own firm's disclosure wording on it?

Yes. The small print is a field like any other, so your standard wording goes in once and prints on every note. The template ships with a plain version to start from; replace it with whatever your compliance function has approved.

Why does the PDF come out so much smaller than the ones from my current tool?

The chart is drawn as vector artwork rather than pasted in as a picture, so it stays sharp at any zoom and its labels stay searchable. A note like this comes to a couple of hundred kilobytes, which matters when you are emailing it to a few hundred people.

Is this market commentary template free?

Yes, with no account, and nothing you type is uploaded. The PDF carries a small BroadPaper line at the foot, which BroadPaper Cloud's paid plan removes.

Free market commentary template · UK

A market note your clients will actually read.

Type the commentary and this week's figures; the note is drawn as you go and downloads as a PDF. Nothing to sign up for, and nothing you type leaves this page.

Your business Business name Address Email Phone VAT or company number

Market commentary details Headline Period Figures as at Written by Standfirst What happened What it means Looking ahead Important information

Markets

Market	Asset class	Level	Change	Year to date	Remove

Free, no account. Nothing you type leaves this page.

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Sending it to every client, every month?

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What the rules ask of a note you send clients

Source: COBS 4.2.1R

It must be fair, clear and not misleading
What counts as clear depends on who is reading it, so a note for retail clients is held to a different standard from one for a professional counterparty
The balance is part of it: a note that reports only what went up is not a fair one, whatever each individual sentence says

This applies to a communication or financial promotion made in the course of designated investment business. A firm that takes reasonable steps to comply has a defence against a private right of action under section 138D (COBS 4.2.6R).

If you show past performance

Source: COBS 4.6.2R

It must not be the most prominent feature of the note
It must cover the preceding five years, or the whole period the investment has been offered, in complete 12-month periods
The reference period and the source of the figures must be clearly stated
A prominent warning must say the figures refer to the past and that past performance is not a reliable indicator of future results
Where the figures are in another currency, say which, and warn that the return may rise or fall with exchange rates
Where the figures are gross, disclose the effect of commissions, fees and other charges

The five-year rule is what catches people out on a weekly note: a one-week or year-to-date table of index levels is an indication of past performance, and showing it alone does not meet 4.6.2R. Your compliance function decides what your firm publishes; this is a summary of the rule, not advice.

A summary to help you decide what to put on a document, not regulatory, tax or legal advice.

Questions

Is a market commentary a financial promotion?: Usually, yes. If it is likely to encourage a client to invest, or to stay invested, it is an invitation or inducement and COBS 4 applies to it — which is why the fair, clear and not misleading rule and the past-performance requirements are worth reading before you publish rather than after.
Can I put my own firm's disclosure wording on it?: Yes. The small print is a field like any other, so your standard wording goes in once and prints on every note. The template ships with a plain version to start from; replace it with whatever your compliance function has approved.
Why does the PDF come out so much smaller than the ones from my current tool?: The chart is drawn as vector artwork rather than pasted in as a picture, so it stays sharp at any zoom and its labels stay searchable. A note like this comes to a couple of hundred kilobytes, which matters when you are emailing it to a few hundred people.
Is this market commentary template free?: Yes, with no account, and nothing you type is uploaded. The PDF carries a small BroadPaper line at the foot, which BroadPaper Cloud's paid plan removes.