It was 24 years ago when Bill Gates said “content is king”. You’d think that’s plenty of time for some networks, compliance managers and planners to develop efficient processes.

    Unfortunately, not. At least in some cases.

    Okay, I’m being deliberately provocative to get your attention.

    Assuming I’ve not offended you and you’re still reading, then great. Let’s have a chat about how everyone involved in the financial promotion approval process can make each other’s lives easier.

    Credentials

    Before I start, it’s probably worth adding some context and establishing my credentials to be able to talk about this subject with a little authority.

    In the dim and distant past, I used to be a financial adviser. I’ve also worked for a network.

    I currently run a marketing agency which produces countless blog articles, newsletters and social media posts for financial planners. We work with over a dozen networks and compliance providers and close to 200 financial planning firms.

    Over the past three years, I’ve seen how some approval processes work efficiently and how others struggle, causing frustration and delay. Hopefully, our experiences can help the whole process work more smoothly.

    The problem

    Many advisers and planners have upped their game when it comes to producing content during the Coronavirus crisis.

    That means more blogs, guides, social media posts, videos and webinars for networks to check and ‘sign off’.

    Let me say here and now that I have huge sympathy with networks and compliance managers.

    Reviewing a tsunami of financial promotions, while transitioning your team to remote working, would be a challenge for even the most diligent of organisations.

    However, even before the current crisis, we’ve identified areas where the financial promotion sign-off process could be improved.

    So, in the spirit of co-operation and partnership, here are our top tips to help all concerned.

    Tips for networks and compliance managers 

    1) Focus on financial promotions

    We’ve seen some networks and compliance managers insist that all blogs are ‘signed off’.

    This extends to even those blogs which bear no resemblance to a financial promotion.

    If one of your team passes an exam, leaves or gets married and you decide to write about it, that isn’t a financial promotion.

    Of course, some will argue it’s impossible to know whether a piece of content is indeed a financial promotion until it’s been read. I get that, but common sense must prevail.

    We rarely see planners complain about the feedback from compliance. However, we regularly see complaints about the speed it takes to review submissions.

    If we can cut the amount of content being sent for approval by excluding anything which clearly isn’t a financial promotion, that’ll reduce the workload. Hopefully it will also speed up the sign-off process for genuine promotions.

    2) Give planners a break on social media

    Things are improving. However, some compliance departments still insist on social media posts being pre-approved.

    In the fast-paced world of social media, when financial planners often need to react to events or the comments of others, that’s ridiculous.

    Again, there’s a simple answer:

    • Financial planners agree not to post financial promotions
    • In return, the compliance department agrees not to require pre-approval on social media posts

    For this to be effective the planner needs to understand what is and isn’t a financial promotion. But if the rules are made clear, with examples of what’s acceptable, that shouldn’t be too hard.

    3) Embrace economies of scale

    If several of your financial planners or appointed representatives (ARs) use the same piece of content, (a blog, guide etc) reviewing it just once would be sensible. After all, the content hasn’t changed from planner to planner.

    Unfortunately, some networks insist that each AR or financial planner submits the content separately. To compound the inefficiency, the same content is often reviewed by different people who request inconsistent changes.

    That means identical content is reviewed multiple times by the same network with a different outcome each time.

    There might be a good reason for this approach, but I can’t think of one.

    It would be more efficient for all concerned if the content were submitted once, reviewed and returned with a single set of changes.  

    4) Standard risk warnings and disclosure

    We often find it’s difficult to keep up with the risk warnings we're required to use by a particular network or compliance manager.

    If we get it wrong, or the financial planner does, that adds time to the approval process.

    Again, there’s a relatively simple solution; keep an up to date list of the risk warnings and standard disclosures required and share it among financial planners, ARs and the firms who provide their marketing.

    Tips for financial planners

    1) Make your compliance team’s life easy

    Experience tells us that the speed at which a compliance department works is directly correlated to how easy you make their life.

    For example, all compliance departments have a process for receiving, reviewing and approving content. They will thank you for understanding their processes, working to them and ultimately making their life easier.

    Give clear instructions and answers too; sometimes brevity helps, but bear in mind it can also be a hindrance leading to confusion and misinterpretation.

    2) Give compliance a ‘heads up’ on big projects

    Submitting a large piece of content such as a guide, video or website to your compliance department and expecting them to review it overnight will lead to disappointment.

    Big projects might only come around relatively infrequently, so naturally, it’s harder to get them right first time.

    So, if you’ve got big projects lined up, give your compliance team a ‘heads up’ with an estimate of when you'll deliver it to them.

    Also, ask for their guidelines and rules before you start the project. It’s better to know where you stand before you start, even if you don’t like the answer!

    3) Work to the rules 

    Understanding the rules prevents you from sending financial promotions which stand no chance of being approved. These will be swiftly returned accompanied by a request for significant amendments.

    It’s only natural that repeat offenders will soon develop a reputation which they will struggle to shake off.

    Far better to know the rules and comply. After all, the sooner your content is approved, the sooner it can start working for you.

    The reward for advisers, networks and compliance managers working in harmony?

    It's simple - everyone wins.

    The financial planner gets their promotion signed off quickly, the compliance department works more efficiently, and everyone’s frustrations are eased.

    Hopefully, these tips will motivate everyone involved to review and improve their processes where necessary. 

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