7 Solutions That Help Achieve Best Practice for Compliance of Financial Promotion Materials

Overview

This solution consists of:

1. A set of principles – developed and agreed by Compliance and Marketing – regarding the way that any content related regulations will be applied
   

2. A set of content compliance rules, guidance and wording that:

   1. Is standardised as far as possible

   2. Are aligned with the principles

   3. Covers all types and formats of content

   4. Will be used by both Marketing and Compliance
      

3. A centralised system – managed by Compliance – that contains details of the content compliance rules, guidance and wording and is used as the foundation for:

   1. Any compliance briefing (solution no. 5)

   2. Any compliance checking system (solution no. 6)

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

How we can help

We can help you with this solution as follows:

• Re point 1:

  • We have a standardised set of principles that can be used as a starting point

  • One of our specialists can work with your Compliance and Marketing leadership to agree a customised set of principles

• Re point 3:

  • Our Compliance Briefing Service involves the creation of a customised set compliance rules, guidance and wording. These are maintained in line with Compliance’s requirements and can be used:

    • To create compliance briefings

    • By a compliance checking system

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Overview

This solution consists of:

1. A set of content compliance objectives – developed and agreed by Compliance and Marketing – that will apply to all content compliance activities

    

2. A set of operating principles – developed and agreed by Compliance and Marketing – regarding the completion of content compliance activities

    

3. A set of best practice processes and procedures that cover all content compliance activities … to include:

   1. Agreed roles and responsibilities (RACI)

   2. Service level agreements (SLAs)

       

4. Management information for all content compliance activities – to include:

   1. Definition of what information is to be provided along with the format and frequency

   2. Responsibility for producing the information

This solution may also address:

• The potential to outsource some compliance related tasks

• Content that is created by 3rd parties and whether those 3rd parties should have any compliance related responsibilities

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

How we can help

We can help you with this solution as follows:

• Re point 1:

  • We have a standardised set of objectives that can be used as a starting point

  • One of our specialists can work with your Compliance and Marketing leadership to agree a customised set of objectives

• Re point 2:

  • We have a standardised set of operating principles that can be used as a starting point

  • One of our specialists can work with your Compliance and Marketing leadership to agree a customised set of principles

• Re points 3 & 4:

  • We have access to a small group of people who specialise in these areas. We would be happy to introduce you to them

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Overview

A Content Creation & Management System (CCMS) is software that enables and supports the creation, management and modification of Marketing and Sales content.

Often, these systems are used for digital media such as website content and social posts. However, this software can be used for producing things such as emails, brochures, presentations and proposals.

For the purposes of this best practice guide, we are using a broad definition to what a CCMS is and what is covers.

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

Different Types of Systems

There are many different types of CCMS and these have differing types of functionality. Here are a few examples of systems that are used for creating and managing content:

• Adobe Experience Manager

• Seismic

• Qvidian

• Microsoft Office suite – Word and PowerPoint

• WordPress

• Canva

Some CCMSs have functionality that supports / enables:

• Planning

• Creation of a brief

• Work allocation and work management

• Storage of assets and content – both during the creation stage and after content has been approved

What’s Important for Achieving Best Practice

In order to help achieve efficient and effective compliance management (i.e. best practice), a CCMS should have functionality that makes it easy to:

1. Reuse (edit / update) existing assets or content

2. Add the required compliance wording – such as disclaimers, warnings and footnotes – into the content

3. Define and control who is able to approve any assets or content (This could be achieved by use of a Work Management System)

4. Update / adjust their content with any changes requested by Compliance

5. Record and manage versions

6. Pass approved content into the content storage system

7. Ensure that only approved content can be published or distributed

How we can help

We can help you with this solution as follows:

• As part of our Compliance Health Check, we can help you:

  • Define and prioritise a comprehensive set of CCMS requirements (as they relate to content compliance)

  • Assess how well your current CCMS solution(s) meet those requirements

  • Identify any important gaps that should be addressed

• Depending on the type of content you are producing, we may be able to introduce you to independent consultants who specialise in relevant content creation & management systems

If you would like to find out more about how we can help ...

Overview

A Work Management Systems (WMS) … sometimes referred to as a “workflow system” - is software that helps organisations to manage projects, tasks, resources, and workflows. 

It provides a centralised platform for planning, tracking, and executing work.

A WMS can help to improve productivity and collaboration, streamline operations and automate processes.

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

Different Types of Systems

There are many different types of WMS and these have differing types of functionality. For example, some systems provide basic “work routing” where the user decides who should complete the next task whilst other systems enable all task management and work routing to be fully automated.

What’s Important for Achieving Best Practice

In order to help achieve efficient and effective compliance management (i.e. best practice), a WMS should have functionality that makes it easy to:

1. 1.     Define the content creation processes and as part of that, define the content compliance related activities or tasks
   

2. Define for each content compliance related activity or task:

   1. Who is authorised to complete it

   2. Any SLA that applies

   3. Record:

      1. Who completed it

      2. When it was completed

      3. How long it took to complete
         

3. Manage / control who is able to complete the approval of any content
   

4. Automate or semi-automate:

   1. The steps where the content creator:

      1. Is provided with or is prompted to retrieve, the “compliance briefing” (i.e. compliance related guidance, rules and wording for the specific content item being produced)

      2. Checks their content before it is submitted for approval. Either, automatically routing the content to the checking step or, prompting the creator to complete the compliance check

   2. The workflow routing e.g. automatically defining the approval route to be used for a specific type of content

   3. Work allocation

   4. Warnings where tasks are overdue or, at risk of being overdue

The WMS should also provide the data that will be used in management information reporting. Some WMS include management reporting capabilities but, others have no or very limited reporting capabilities.

Note. Having complete, accurate and up to date data regarding the compliance related activities and tasks, is critical to achieving best practice. For example, it is critical to understand:

• How long it takes (minutes / hours) to update content to meet the compliance requirements

• What % of cases fail the approval step

Some Work Management Systems include integration functionality that makes it easier to:

• Find existing assets or content for reuse

• Upload or save the final approved content into the asset storage and management system

It is worth noting that “work management” capabilities / functionality are often included in:

• Content Management Systems

• Asset Storage and Management Systems

Equally, some Work Management Systems provide functionality that are provided by:

• Content Management Systems

• Asset Storage and Management Systems

How we can help

We can help you with this solution as follows:

• As part of our Compliance Health Check, we can help you:

  • Define and prioritise a comprehensive set of WMS requirements (as they relate to content compliance)

  • Assess how well your current WMS solution(s) meet those requirements

  • Identify any important gaps that should be addressed

• Once we understand your requirements, we will be able to introduce you to several different WMS suppliers who are likely to be suitable for you

If you would like to find out more about how we can help ...

Overview

A good “compliance briefing” defines everything that is needed for any financial promotion content to be compliant.

This includes:

• The specific wording to be used in the content – including disclaimers / disclosures, warnings and footnotes

• Guidance about where wording should be located and how it should be displayed

• Guidance covering all other compliance requirements – including aspects such as tone of voice, readability and use of jargon or abbreviations

The “compliance briefing” is used by content creators to:

• Obtain all of the content specific compliance wording that needs to be included in their content

• Understand where the compliance wording needs to be located and how it needs to be displayed

• Understand all other compliance aspects that are relevant to the specific content

A “compliance briefing” can also be used as a checklist by:

• Content creators – to check their content before they submit it for approval

• Content approvers – to make it easier for them to understand what the compliance requirements are for any content / material

Note.

• A good “compliance briefing” addresses the root cause of most content compliance issues because it:

  • Gives the content creator everything they need to ensure that the content is fully compliant and therefore, will be approved 1st time

  • Significantly reduces the time needed by creators to meet the compliance requirements

• The compliance briefing could be provided as part of the content briefing given to any 3rd party content creator. This opens up the possibility of the 3rd party being responsible for updating the content to meet the compliance requirements.

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

Different Types of Systems

Many organisations have developed their own in-house systems (normally Excel based) that provide some elements of a full “compliance briefing”.

These are usually helpful but, because these are not normally comprehensive or standardised, they often do not meet the best practice standard. They can also be relatively expensive to maintain.

What’s Important for Achieving Best Practice

In order to help achieve efficient and effective compliance management (i.e. best practice), a “compliance briefing” should:

• Be easy for the user to request / generate
  

• Be able to be used for any financial promotion and therefore, should cover all:

  • Formats

  • Types

  • Jurisdictions

  • Product types

  • Regulations

  • Languages etc.
    

• Be created using the standardised guidance, rules and wording as defined / agreed in Solution 1 (Standardised Compliance Guidelines, Rules & Wording)
  

• Cover all of the compliance requirements – not a sub-set of them
  

• Be in a format suitable for both experienced and inexperienced staff. That is:

  • Provide compliance guidance and compliance information in a format that is easy for inexperienced staff to understand and use

  • Enables experienced users to quickly find and use only the specific information they need
    

• Provide the required compliance wording in a format that is easy for the content creator to add into their content; or

• Clearly explain where compliance information needs to be located and how it needs to be displayed

The most efficient and effective solution is one where the wording from the compliance briefing is automatically inserted into the content (via integration with a Content management System). However, the cost of this integration is not always affordable, and a fully integrated solution often only makes sense for organisations who are generating a large volume of content.

How we can help

We can help you with this solution as follows:

• As part of our Compliance Health Check, we can help you:

  • Define the requirements for a “compliance briefing”

  • Assess how well any current “compliance briefing” solution(s) meet those requirements

  • Establish if there is a need to enhance any current solution or find a new solution

• Through our Compliance Briefing Service, we can provide you with “compliance briefings” that meet all of the best practice requirements

If you would like to find out more about how we can help ...

Overview

A compliance checking system is software that checks content to establish if it meets the compliance requirements.

A content checking system can be used by:

• Content creators to check their content before submitting it for approval

• Content approvers to check any content sent to them

A content checking system can:

• Reduce the risk of non-compliant content being sent to approvers by creators

• Reduce the time that approvers need to check content

• Reduce the risk of non-compliant content being approved by mistake

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

Different Types of Systems

There are many different types of content checking systems and these have differing capabilities / functionality. For example:

• Most systems can check if the content contains specific wording (e.g. a disclaimer) but, many systems are not able to check:

  • If that wording is in the correct location

  • For similar wording – if the exact wording has not been found
    

• Some systems can check data that is in a table but, other can’t
  

• Some checking systems include basic workflow capabilities that enable content to be routed between content creators and content approvers
  

• Some systems include functionality that enables the approver to mark up the content that they are reviewing
  

• Some systems only support English content whereas others have multi language capabilities
  

• Some systems can only check PDF documents whilst others can check a range of different formats

One very important difference between systems is the way in which they determine what is compliant and what is not. Some systems use AI to interpret the regulations and to learn from the results of previous reviews. Others, require all of the individual rules to be set-up in the system. These differences make a very big difference to:

• The time and cost of setting up the system

• The range of checks that can be carried out and the accuracy / reliability of those checks

What’s Important for Achieving Best Practice

In order to help achieve efficient and effective compliance management (i.e. best practice), a content checking system should:

1. Be able to easily align to (i.e. use) the organisation’s compliance rules and wording
   

2. Have an easy and effective way of determining which rules and wording apply to the specific content item that is being checked
   

3. Be able to check a wide range of content types and content formats
   

4. Support a wide range of checks. For example, being able to check:

   1. Whether the required wording (e.g. disclaimers, warnings and footnotes) are:

      1. In the content

      2. In the required location

      3. Correctly displayed

   2. Information held in graphs and tables

   3. For the presence of words or phrases that are unacceptable or should be used with caution

   4. If jargon or abbreviations have been used (and if they have been properly explained)
      

5. Provide an easy way for a user to understand:

   1. What has been checked

   2. The results of the checks

   3. The reason why any check has highlighted something as non-compliant
      

6. Provide an easy way for a reviewer / approver to provide their feedback regarding the checks that have been carried out

How we can help

We can help you with this solution as follows:

• As part of our Compliance Health Check, we can help you:

  • Define and prioritise a comprehensive set of requirements for a compliance checking system

  • Assess whether there is a good business case for the use of a compliance checking system

• Our Compliance Checking Service. This is an on-demand service which provides a very comprehensive set of checks and meets the best practice requirements

If you would like to find out more about how we can help ...

Overview

A “Digital Asset Management” (DAM) is a software system that is used to manage digital files, such as images, videos, and documents, in a central and organised way. 

A DAM is used to efficiently store, manage, retrieve, and distribute digital content. 

Examples of what most DAMs enable or support are:

• Providing a single, secure location for all digital assets. 

• Allowing users to organize assets using tags, keywords, and other metadata

• Searching, retrieval and viewing of existing assets

• Version management and control

• Distribution of assets to different channels and in different formats e.g. websites, social media, and print

• Controlling access to and use of any asset

For information about the above activities, please refer to our Best Practice Guide for Managing Compliance of New Financial Promotion Materials.

Different Types of Systems

There are many different types of DAM and these have differing types of functionality – ranging from basic to very advanced.

It is important to note that many Work Management Systems and Content Management Systems also include DAM functionality.

What’s Important for Achieving Best Practice

In order to help achieve efficient and effective compliance management (i.e. best practice), a DAM should have functionality that makes it easy to:

1. Upload new content that has passed the approval process
   

2. Record compliance related information for every approved asset or content item. For example:

   1. Version

   2. Approval ID

   3. Approval date

   4. Expiry date
      

3. Find existing assets or content that are compliance approved and which:

   1. Could be reused as part of content creation (i.e. edited / updated)

   2. Can be distributed or published
      

4. Define and control:

   1. Who can access any asset or content

   2. The audience for any asset or content
      

5. Manage content against its expiry date – including, blocking use of any content that has passed its expiry date
   

6. Control who is able to update expiry dates
   

7. Ensure that only approved content can be published or distributed

Some DAMs have functionality that supports / enables:

• Workflow and work management

• Content creation

How we can help

We can help you with this solution as follows:

• As part of our Compliance Health Check, we can help you:

  • Define and prioritise a comprehensive set of DAM requirements (as they relate to content compliance)

  • Assess how well your current DAM solution(s) meet those requirements

  • Identify any important gaps that should be addressed

• Depending on the type of content you are producing, we may be able to introduce you to independent consultants who specialise in relevant DAM systems

If you would like to find out more about how we can help ...