FCA has published advice to investors who lost money investing in Secured Energy Bonds plc mini-bonds. The advice notes that, although the issuer was (and did not need to be) regulated, mini-bonds are themselves financial instruments, and so any authorised firm that approves financial promotions in respect of them must comply with FSMA and COBS requirements. In this case Independent Portfolio Managers Ltd, now in liquidation, approved the promotions. Although the firm is in liquidation, it is covered by FSCS, so any investor with a valid claim about a misleading financial promotion may be eligible for compensation. The note should serve as a warning to firms asked to approve promotions for products that are regulated investments, yet sold by unregulated firms (even where the selling mechanism is legitimate).