For anyone joining the industry from an unregulated one, the need for compliance approval of marketing materials can be an eye-opener. If you’re a marketing manager in a regulated sector – such as financial services – ‘compliance’ is a word you’ll be very familiar with. Outside the regulated world, you just need approval from your business leaders and you’re good to go.
Not the case in a regulated industry.
Whether you’re governed by the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA) or any other regulator – getting the right sign-off is key.
Any marketing materials – or ‘financial promotions’ as they are termed by the FCA – need sign off from an appropriate person in your firm. Activity that falls under this heading includes:
- Direct mail
- Email marketing
- Social media – posts on Twitter, Linkedin, Facebook, Instagram, Pinterest or any other platform
- Web content
- Whitepapers, reports or other thought leadership
If you’re new to regulated industry marketing, this can be a whole new world.
Having to secure approval can impact your lead time. You need to bear this in mind when planning activity.
And getting sign-off is just one part of the jigsaw.
You also need to make sure the entire process, including any changes and versions of your promotion, is properly documented to provide an audit trail.
This audit trail is vital if the FCA decide to visit your firm, as it will provide evidence that you have followed the correct sign-off procedure before publishing.
All of this creates an extra layer of marketing admin in terms of the management, tracking and documenting of the approvals process.
If you want to ensure your promotions meet the regulator’s requirements, you need to understand:
- Why are financial promotions so heavily regulated? Understanding this will help you appreciate the reasons behind some of the changes required for sign-off – and may help to pre-empt them.
- What is the FCA looking for? Having a clear understanding of what the FCA will take issue with helps you to create marketing materials that will get sign-off first time, with minimal revisions to slow you up.
- What’s the difference between a ‘non real-time’ and a ‘real time’ financial promotion? Different types of activity are regulated differently, and need different levels of approval. Develop an understanding of this and make sure you get the necessary approvals.
- What is the role of your Compliance team and how can you work together? A close relationship between these two teams is vital. Understanding each other’s role and objectives helps hugely
- What are the common pitfalls? Understand the things that will see your promotions rejected and you will minimise amendments and rework.
- Are there any regulatory changes planned? Knowing what’s coming down the pipeline can help with planning future activity.
Source: Perivan Solutions
If you are unsure how your activities fits within the rules mentioned within this article, please take advantage of our Financial Promotion Review service.
Pages of interest:
- Smarter Consumer Communications: a further step in the journey
- Social Media & Financial Promotions
- Automated Workflow
- Marketing Support
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