You read a CLIENT-FACING MARKETING PIECE -- a factsheet, a pitch page, a client email -- and return a REVIEWER'S WORKSHEET of the claims in it. You return JSON and nothing else.
You are preparing a worksheet for a qualified reviewer. You never approve a piece, never reject one, never sign one off, never clear one for distribution, never file anything and never record a sign-off. NOTHING YOU RETURN MAKES A PIECE APPROVABLE. Your job is to say what the piece states, apply the checklist given below, and NAME THE CLAIMS THE CHECKLIST DOES NOT SETTLE.
RULES, in order of importance:
1. ONE OBJECT PER CLAIM IN THIS VERSION OF THIS PIECE, AND NO OTHERS. A claim withdrawn by the Review Notes is not made by this version, even though its whole block is still printed. A specimen in the House Style Specimen appendix is an example shown to staff and is made to nobody. A claim carried in the previous version and referred to here for context belongs to that version. All three carry codes in the same format as a real claim, and putting one on the worksheet puts a claim in front of a reviewer that this piece does not make.
2. REPORT WHAT THE PIECE STATES. `claim_kind`, `asserted_by`, `note_placement` and `time_frame` are readings of the piece, not judgements about it. `claim_kind` is copied verbatim from the Kind line of the claim's own block.
3. `note_placement` IS THE HARDEST FIELD AND THE ONE TO SLOW DOWN ON. Every note in a piece is printed as `Note for MC-nnnn: ...`, naming the claim it accompanies. For each claim, find the checklist item that governs its kind, read what that item REQUIRES, and then look for a note tagged with THIS claim's code that actually says that. If it is inside this claim's own block, 'in_this_block'. If it is somewhere else in the piece -- the Important Information footer, the note under the Performance Summary table, or inside a DIFFERENT claim's block -- 'elsewhere_in_piece'. If no note tagged to this claim says what the item requires, 'not_in_this_piece'. A NOTE TAGGED TO THIS CLAIM THAT BELONGS TO A DIFFERENT ITEM DOES NOT COUNT: a note about periods that have already ended does not cover a modelled figure, however adjacent it is.
4. `disclosure` IS DECIDED ONLY BY THE CHECKLIST BELOW, from `claim_kind`, `asserted_by` and `note_placement`. Work through the seven steps IN ORDER and STOP at the first that fires:
a. asserted_by 'third_party' -> 'not_required'.
b. a kind the checklist has no item for -> 'not_determined'.
c. asserted_by 'not_stated' -> 'not_determined'.
d. note_placement 'in_this_block' -> 'carried'.
e. note_placement 'elsewhere_in_piece' AND the item lets the note sit anywhere -> 'carried'.
f. note_placement 'elsewhere_in_piece' AND the item wants the note beside the claim -> 'not_carried'.
g. note_placement 'not_in_this_piece' -> 'not_carried'.
5. THE NOTE BEING SOMEWHERE ON THE PAGE IS NOT THE SAME AS THE ITEM BEING MET. Step (f) is the one a confident reader skips: the words are there, in the footer or under the table or beside another claim, and the item asks for them beside THIS claim. On this checklist that is the wrong answer rather than a defensible one.
6. `not_required` AND `not_determined` ARE DIFFERENT ANSWERS AND YOU ARE EXPECTED TO USE BOTH. `not_required` means the checklist was worked through and lands on nothing being needed. `not_determined` means the checklist does not settle it at all -- and a worksheet that never reaches for it is guessing, because a claim recorded as settled is a claim nobody re-reads.
7. `horizon` IS DECIDED ONLY FROM `time_frame`: 'period_ended' -> 'historical', 'future_outcome' -> 'forward_looking', 'no_period' -> 'not_determined'. It is asked of every claim independently of its disclosure call. READ THE PERIOD, NOT THE TENSE.
8. Copy `claim_code`, `claim_label` and `claim_kind` verbatim from the piece. Use the exact allowed value for every field that lists them, and return every field for every claim.
REVIEW CHECKLIST (the authority for `disclosure` and `horizon`; this is an ILLUSTRATIVE checklist written for this kit -- it is not any regulator's rule, any supervisor's guidance, any trade body's code or any firm's compliance manual, and the item codes were invented here)
WHAT COUNTS AS A CLAIM ON THE WORKSHEET
- A claim is on the worksheet if and only if it is a coded claim in THIS VERSION of THIS PIECE - a row of the piece's Claim Schedule.
- A claim withdrawn from this version by the review notes is NOT on the worksheet, even though its code and its whole block are still printed in the piece.
- A specimen claim printed in the House Style Specimen appendix is NOT on the worksheet. It is an example of how to write a claim, shown to staff. It is not addressed to any client and it is not made by the piece.
- A claim carried in an EARLIER approved version of this piece and referred to here for context is NOT on the worksheet. It is a different piece's paperwork.
THE CHECKLIST'S ITEMS -- one governs each claim, chosen by the claim's KIND
MRC-1 performance_figure note must be adjacent -- a note saying the figures are for periods that have ended and do not indicate what will be returned in future
MRC-2 hypothetical_figure note must be adjacent -- a note saying the figures were modelled rather than earned, that no client account was managed on that basis over the period shown and that no investor received them
MRC-3 forward_statement note must be adjacent -- a note saying the outcome is not assured and may not be achieved
MRC-4 superlative note must be anywhere -- a note naming the source of the ranking, the date it was awarded and the population it covered
MRC-5 fee_basis note must be anywhere -- a note saying which charges the figure is stated after and which it is stated before
MRC-6 track_record note must be adjacent -- a note saying what period the record covers and that it includes every account managed on the strategy over it
(no item) service_description the checklist covers no claim of this kind
THE FOUR STATED FACTS, read off the piece
claim_kind:
performance_figure the piece's Claim Schedule labels this claim a stated return figure for a period that has ended
hypothetical_figure the schedule labels it a modelled, simulated or backtested figure
forward_statement the schedule labels it a statement about a future outcome
superlative the schedule labels it a ranking, award or best/largest/leading claim
fee_basis the schedule labels it a figure stated after or before a charge
track_record the schedule labels it a claim about the length or continuity of a record
service_description the schedule labels it a plain description of what the firm or fund does
asserted_by:
firm the claim's own block states the firm as the source, or states no source other than the firm itself
third_party the block names an external source and reports the claim AS that source's - a ranking awarded by a named body, a figure published by a named data provider
not_stated the block attributes the claim to nobody at all, naming neither the firm nor any external source
note_placement:
in_this_block the note this claim's own item requires appears inside this claim's block
elsewhere_in_piece that note appears somewhere else in the piece - the Important Information footer, the note under the performance table, or inside a DIFFERENT claim's block
not_in_this_piece that note appears nowhere in the piece. A note belonging to a DIFFERENT item sitting beside this claim does not change this value: it is not the note this item requires
time_frame:
period_ended the claim is about a period that has already ended
future_outcome the claim states an outcome in a period that has not happened yet, HOWEVER it is worded - a sentence in the past or present tense that says what will be delivered is a future outcome
no_period the claim names no period at all
THE DISCLOSURE CALL -- work through IN ORDER, stop at the first that fires
1. REPORTED, NOT ASSERTED. If asserted_by is `third_party`, the worksheet records `not_required`. The items in this checklist attach to claims the FIRM makes; a ranking or a figure the piece reports as a named external source's, and attributes to that source, is not one. This is settled, and it is not the same answer as `not_determined`.
2. NO ITEM COVERS IT. If claim_kind is one this checklist has no item for, the worksheet records `not_determined`. Nothing in the checklist says what must accompany that kind of statement, so the checklist does not settle it. THIS IS A FINDING ABOUT THE CHECKLIST, not about the piece, and it is the row a reviewer most needs to see - it is where their own judgement is required and no list is going to help them.
3. NOBODY IS NAMED. If asserted_by is `not_stated`, the worksheet records `not_determined`. Step 1 turns on whose claim it is and the piece does not say, so the checklist cannot be worked through to an answer.
4. THE NOTE IS WITH THE CLAIM. If note_placement is `in_this_block`, the worksheet records `carried`.
5. THE ITEM ALLOWS IT ANYWHERE. If note_placement is `elsewhere_in_piece` AND the governing item's placement is `anywhere`, the worksheet records `carried`. Two items in this checklist are written that way - MRC-4 and MRC-5 - because a source line and a charges line are read once for the whole piece.
6. THE NOTE IS IN THE PIECE AND STILL NOT WITH THE CLAIM. If note_placement is `elsewhere_in_piece` AND the governing item's placement is `adjacent`, the worksheet records `not_carried`. THIS IS THE STEP A CONFIDENT READER SKIPS. The note is on the page. It is in the footer, or under the table, or beside a different claim. The item asks for it beside THIS claim and it is not there, so on this checklist the item is not met - and a reader scanning for whether the words appear at all will tick it.
7. THE NOTE IS NOT IN THE PIECE. If note_placement is `not_in_this_piece`, the worksheet records `not_carried`. A note belonging to a different item sitting right beside the claim does not save it: a modelled figure is not covered by a note about periods that have ended, however adjacent that note is.
THE HORIZON CALL
1. If time_frame is `period_ended`, the worksheet records `historical`.
2. If time_frame is `future_outcome`, the worksheet records `forward_looking`. WORDING DOES NOT DECIDE THIS. A sentence written in the past or the present tense that states what a strategy will deliver over a period that has not happened is a forward-looking statement, and reading the tense instead of the period is the commonest way to get this column wrong.
3. If time_frame is `no_period`, the worksheet records `not_determined`. The horizon question is asked of every claim independently of the disclosure call - a claim whose note is perfectly placed still either names a period that has ended, a period that has not, or none at all.
WHY `not_determined` IS A REAL ANSWER
A worksheet that never says `not_determined` is not a thorough worksheet, it is a guessing one. The whole value of this shape is that a reviewer can see, in one column, which claims the checklist actually settles and which ones need a person to think. Over-confidence here costs more than caution in both directions: a claim recorded as settled is a claim nobody re-reads, and a checklist stretched over a claim it does not cover produces a tick that means nothing. `not_required` is a different answer again - it means the checklist WAS worked through and it lands on nothing being needed.
Return these:
- piece_ref (string) -- the piece reference from the Piece section, verbatim
- claims (array of objects) -- one object per claim THIS VERSION makes, each carrying:
- claim_code (string) -- the claim code from the Claim Schedule row, verbatim (for example MC-4417). THIS IS THE KEY -- one object per claim in THIS VERSION of this piece and no others
- claim_label (string) -- the claim's short description, copied verbatim from the Summary line of the claim's own Claim block
- claim_kind (enum) one of: performance_figure, hypothetical_figure, forward_statement, superlative, fee_basis, track_record, service_description -- the claim kind, copied verbatim from the Kind line of the claim's own Claim block. The piece states it; you are not asked to re-classify the claim
- asserted_by (enum) one of: firm, third_party, not_stated -- who the claim's own block states is making the claim. 'third_party' when the block names an EXTERNAL source -- a ranking body, a data provider, a research house -- and reports the claim as that source's. 'firm' when the block states the firm as the source, or states no source other than the firm itself. 'not_stated' when the block names nobody at all, neither the firm nor any external source. Read the block; never infer an attribution from how confident the claim sounds
- note_placement (enum) one of: in_this_block, elsewhere_in_piece, not_in_this_piece -- WHERE THE NOTE THIS CLAIM'S OWN CHECKLIST ITEM REQUIRES APPEARS -- and this is the hardest field on the worksheet. 'in_this_block' when that note is inside this claim's own Claim block. 'elsewhere_in_piece' when it appears somewhere else in the piece: the Important Information footer, the note printed under the Performance Summary table, or inside a DIFFERENT claim's block. 'not_in_this_piece' when that note appears nowhere in the piece. ⚠ A NOTE BELONGING TO A DIFFERENT ITEM SITTING RIGHT BESIDE THIS CLAIM DOES NOT COUNT -- read what the note actually says against what this claim's item requires. A note about periods that have ended does not cover a modelled figure, however adjacent it is. Where the checklist has no item for the claim's kind, there is no such note and the value is 'not_in_this_piece'
- time_frame (enum) one of: period_ended, future_outcome, no_period -- the PERIOD the claim is about. 'period_ended' when it is about a period that has already finished. 'future_outcome' when it states an outcome in a period that has not happened yet -- HOWEVER IT IS WORDED. A sentence in the past or present tense that says what a strategy will deliver over the coming years is a future outcome; reading the tense instead of the period is the commonest way to get this wrong. 'no_period' when the claim names no period at all
- disclosure (enum) one of: carried, not_carried, not_required, not_determined -- the worksheet's disclosure call for this claim, decided STRICTLY by the shipped checklist from `claim_kind`, `asserted_by` and `note_placement` and nothing else. Work through the seven steps IN ORDER, stopping at the first that fires. (1) asserted_by 'third_party' -> 'not_required'. (2) a kind the checklist has no item for -> 'not_determined'. (3) asserted_by 'not_stated' -> 'not_determined'. (4) note_placement 'in_this_block' -> 'carried'. (5) note_placement 'elsewhere_in_piece' AND the item allows the note anywhere (MRC-4, MRC-5) -> 'carried'. (6) note_placement 'elsewhere_in_piece' AND the item requires the note beside the claim -> 'not_carried'. (7) note_placement 'not_in_this_piece' -> 'not_carried'. THE NOTE BEING SOMEWHERE ON THE PAGE IS NOT THE SAME AS THE ITEM BEING MET: step 6 is the one a confident reader skips
- horizon (enum) one of: historical, forward_looking, not_determined -- the worksheet's horizon call, decided STRICTLY from `time_frame`: 'period_ended' -> 'historical', 'future_outcome' -> 'forward_looking', 'no_period' -> 'not_determined'. Asked of every claim independently of its disclosure call
Return a JSON object with exactly these top-level keys: piece_ref, claims
`claims` is an array. Return it empty only if this version of the piece makes no claim at all.
MARKETING PIECE
---------------
Piece
-----
Piece reference: MP-2024-134
Extract id: MRV-0034
Piece kind: campaign landing page
Piece date: 2024-02
Intended audience: existing clients
This extract is prepared for marketing review. The Schedule Of Claims below lists the coded
claims THIS VERSION of the piece makes. The Claim blocks that follow set each of them out.
Schedule Of Claims
------------------
------------------------------------------------------------------------------------------
CODE KIND SUMMARY
------------------------------------------------------------------------------------------
MC-8162 performance_figure Fennimore Global Equity Fund's stated return
MC-4032 hypothetical_figure Windermarsh Absolute Return strategy's modelled return
MC-2150 superlative Kirtlow Diversified Fund ranked against its sector
MC-8629 performance_figure Rossmere Balanced Fund's stated return
MC-7606 forward_statement What Fennimore Balanced Fund is said to deliver next
------------------------------------------------------------------------------------------
Performance Summary
-------------------
------------------------------------------------------------------------------------------
CLAIM BASIS FUND OR STRATEGY RETURN BENCH
------------------------------------------------------------------------------------------
MC-8162 actual Fennimore Global Equity Fund 6.4% 1.5%
MC-4032 modelled Windermarsh Absolute Return stra 5.7% 4.0%
MC-8629 actual Rossmere Balanced Fund 3.4% 5.6%
------------------------------------------------------------------------------------------
Claim MC-8162
-------------
Summary: Fennimore Global Equity Fund's stated return
Kind: performance_figure
Fennimore Global Equity Fund investors saw a return of 6.4 per cent a year across the 2021 to
2023 period, compared with 1.5 per cent for the Northbank Composite. That is the return the
Fennimore Global Equity Fund will go on delivering through to 2028.
The years in question are 2024 through 2028.
Note for MC-8162: The figures shown for this claim are for periods that have already ended.
They are not an indication of what will be returned in any future period.
Claim MC-4032
-------------
Summary: Windermarsh Absolute Return strategy's modelled return
Kind: hypothetical_figure
A model portfolio run on the Windermarsh Absolute Return strategy across 2019 to 2023 produces
5.7 per cent a year, against 4.0 per cent for the Northbank Composite.
This claim is made by Holmsdale Investment Management on the basis of its own records.
The period covered closed before this piece was written.
Claim MC-2150
-------------
Summary: Kirtlow Diversified Fund ranked against its sector
Kind: superlative
The Kirtlow Diversified Fund is the top-rated fund of its kind.
The figure is published by Pentworth Data and is reproduced here as that provider's, not as a
claim by Holmsdale Investment Management.
Claim MC-8629
-------------
Summary: Rossmere Balanced Fund's stated return
Kind: performance_figure
Over the 2021 to 2023 period the Rossmere Balanced Fund grew by 3.4 per cent a year, ahead of
the Northbank Composite at 5.6 per cent.
The figure is published by Verrell Research and is reproduced here as that provider's, not as
a claim by Holmsdale Investment Management.
The record above runs to the end of 2023.
Note for MC-8629: The figures shown for this claim are for periods that have already ended.
They are not an indication of what will be returned in any future period.
Claim MC-7606
-------------
Summary: What Fennimore Balanced Fund is said to deliver next
Kind: forward_statement
The Fennimore Balanced Fund delivers 10.8 per cent a year across a full cycle, and the cycle
running from 2024 to 2027 is no exception.
The years in question are 2024 through 2027.
Important Information
---------------------
This piece is issued by Holmsdale Investment Management. It is addressed to existing clients.
The value of an investment and the income from it can fall as well as rise.
Note for MC-2150: The ranking in this claim was awarded by the source named, on the date
shown, on that source's own criteria, and covered only the firms that entered.
END OF EXTRACT MRV-0034
Prepared for marketing review. This extract is generated and describes no real firm, fund,
strategy, benchmark, ranking or person. Nothing in it approves, clears or rejects anything.