By: Julie Galbraith, Guest Blogger and Compliance Liaison
Published June 13, 2018
Every financial advisor understands the importance of compliance for any prospective advertising content, to ensure it is not misleading and meets compliance requirements. We know the process well: you have a great idea for your social media channels or a blog. You spend time carefully crafting your message with your audience in mind, and finally, after reworking and finalizing, you submit to compliance. You receive an advertising review tracking number for each submission. But here’s the thing about this process: it is thoroughly documented. Advertising review tracking numbers are like bad pictures on Facebook. You can put as many up as you like, but the bad ones will always come back to haunt you. What I mean is, if there is a tracking number out there that isn’t complete or is not approved, or came back needing further information, it can be pulled into an audit by any regulator as an unfinished or incomplete item. Not just for you but for your OSJ or broker-dealer as well! It’s like the picture you put up on social media for throwback Thursday a few years ago to be funny, with the 80’s hair, and you forget about it until a new friend points it out again. “Whoa… that’s a lot of hairspray.”
Abandoned Content Stuck in Compliance Poses Big Problems for Advisors
In most cases, we are finding that people will make any changes, and then upload the final version to a new tracking number, but then the old one is still out there like the bad picture; just waiting to be pointed out. Or maybe you put something through your compliance review system, and then don’t use it after the review because you don’t want to make all the changes. That item, regardless if used or not, sits out there as an unfinished item until it is marked “Did Not Use” or the final is completed. These abandoned tracking numbers can become a bigger issue to fix, especially if they aren’t caught at the next audit. The question “Who did you send this unfinished item to five years ago?” might be quite daunting as our memory runs short. When you don’t have a final version, it will be a hard question to answer.
A best practice would be to mark the piece of collateral as “Did Not Use.” This eliminates the problem, and it’s an easy fix. After all, friends don’t let friends share pictures of mall bangs and acid washed jeans! Be sure to take a look in your advertising review archive today and clean it up! Your future self will thank you when it comes time for an audit.
Julie Galbraith is a Compliance Liaison at Private Advisor Group, working with our network of advisors on their advertising and marketing reviews from a compliance viewpoint. She will be providing helpful tips in advertising and marketing on a quarterly basis.