A clip can explain how the yield is generated. It should not quote a number as though it were a promise. The line regulators keep drawing is between explaining and enticing — the UK test, for instance, turns on whether the communication is an invitation or inducement. “Here is where the yield comes from, and what happens if the collateral ratio breaks” is explanation. “Earn 14% APY” is an inducement, and it moves your clip out of educational content and into a financial promotion.
In practice that is the do-not-say list: no fixed APY figures, no “risk-free” or “guaranteed”, no “passive income”, no projected returns, and no referral or affiliate link inside the clip. That last one catches teams out — an otherwise educational clip carrying a referral code can become a promotion.
We hold this line even when a client pushes, for two reasons. The enforcement risk is yours, not ours: the SEC’s action against BlockFi turned on a false and misleading statement about the risk level of its loan portfolio published on its own site. And commercially, a clip that explains the mechanism selects for depositors who stay when rates move, while a clip that leads with a number selects for the ones who leave when a better number appears.
General information on where marketing rules sit, not legal advice. Rules differ by jurisdiction — have your own counsel set the final lines, and we will put them in the brief.