Marketing and the Compliance Review:
One of the ongoing tasks of the Compliance Department is the infamous and generally last minute marketing materials review. Often it takes place under urgent and rushed conditions in which Compliance “comes to the rescue” getting comments in just in time to get the document out the door.What will make these moments less tense and problem free is the development of a comprehensive marketing review policy and a training program. The marketing policy should do two basic things: (1) identify the approval routing process; and (2) set out the content requirements, inclusive of specific disclosure statements. Once the process is established, then a training program in which the Compliance educates the business units on regulatory requirements should be implemented.
This training will go a long way to making sure that everyone is aware and understands the requirements, thereby reducing the need for last minute revisions.
If your firm is small, or your personnel are extremely pressed for time, review of marketing materials is a task that can be easily outsourced to a consultant. Once the consultant gets to know your business and your materials, this is one of the easier tasks to outsource.