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Part 2 - Best Practice Guide to Managing Compliance of New Financial Promotion Materials
- Dave Moore
- May 30
- 6 min read
This Guide is part of our Best Practice Guide to Managing Compliance of New Financial Promotion Materials.
If you have not already done so, we recommend that you first read the Introduction Section of this Guide. That explains the purpose of the Guide covers and how to use it.
Purpose of the Planning & Briefing Activity
The business purpose of the Planning & Briefing activity is to … define the plan for creating the content with that plan including, what needs to be done, when it needs to be done and who will be responsible.
This activity also includes briefing the people who will be responsible for creating the content.
Marketing are normally responsible for this activity
It is best practice to consult with any areas who have responsibilities for delivering the planned activities. e.g. Compliance
Compliance Related Objectives
The main content compliance related objectives for this activity are:
To ensure that the plan:
Includes all compliance related activities / tasks
Includes ways of getting both early and ongoing input and advice from Compliance regarding Marketing’s ideas or concepts
Gives Compliance an opportunity to provide their input / suggestions to Marketing regarding:
Ways of meeting the regulatory requirements
Approaches being used by competitors
Includes an activity to identify compliance approved assets or content that could be reused (i.e. to avoid “reinventing the wheel”)
Aligns compliance activities and tasks with the agreed RACI and SLAs (This includes, ensuring that the time allocated for compliance activities, is realistic)
Includes a step where the content creator has to confirm that their content meets all compliance requirements, before the content is submitted for approval
To agree the point in the content creation process, when the compliance requirements will be finalised. That is, when the compliance briefing will be produced
To ensure that the content briefing, takes all compliance requirements into account
Overall, the objectives are to:
Maximise the likelihood that any content that is produced, will be compliant and therefore, will pass the approval process with no or very little amendment / rework
Ensure that everyone who has a compliance related responsibility for the content, is aware of what is expected of them and when they will be required to do anything
Minimise wasted time / effort for both Marketing and Compliance
Maximise the use of existing assets / content and therefore, minimise money spent on 3rd parties (e.g. assets purchased or content creation work done)
Best Practice – Key Elements and Potential Solutions
This section lists the key elements of best practice for this activity and shows for each element:
Which level of best practice they are part of – Standard or Advanced
The solutions that are likely to enable the best practice element to be achieved. (More information about these solutions, can be found in this guide - 7 Solutions That Help Achieve Best Practice)
No. 1 - Operating Principles
There is a set of operating principles – developed and agreed by Compliance and Marketing – regarding the completion of content compliance activities
Level:
Standard
Advanced
Potential solution(s):
Operating Model
No. 2 - Processes & Procedures
There is a set of best practice processes and procedures that cover all content compliance activities … to include:
Agreed roles and responsibilities (RACI)
Service level agreements (SLAs)
Level:
Standard
Advanced
Potential solution(s):
Operating Model
No. 3 - Plan for Compliance
The plan includes all compliance activities as set out in the best practice processes and procedures – including, the agreed SLAs
Level:
Standard
Advanced
Potential solution(s):
Operating Model
Work Management System
No. 4 - 3rd Party Content Creation
If content creation is being outsourced to a 3rd party, the planning activity will decide who will be responsible for updating the content to meet the compliance requirements – Marketing or the 3rd party
Level:
Standard
Advanced
Potential solution(s):
Operating Model
No. 5 - Briefing 3rd Party Content Creators
Where content creation is being outsourced to a 3rd party, they are provided with a “compliance briefing” and are responsible for updating the content to meet the compliance requirements
Level:
Advanced
Potential solution(s):
Operating Model
Compliance Briefing
No. 6 - Ongoing Compliance Input
The plan ensures that Compliance are actively involved in assessing Marketing’s designs or concepts as they evolve … providing early input / feedback especially regarding any aspects that might be deemed to be risky or non-compliant
Level:
Standard
Advanced
Potential solution(s):
Operating Model
Compliance Briefing
No. 7 - Dealing With Disagreements
There is an agreed process and RACI for quickly resolving any points where there is disagreement between Marketing and Compliance
Level:
Standard
Advanced
Potential solution(s):
Operating Model
No. 8 - Reuse of Existing Content
The plan includes a step for identifying any existing compliance approved assets or content that can be reused
Level:
Standard
Advanced
Potential solution(s):
Compliance Briefing
Work Management System
Digital Asset Management System
No. 9 - Reuse of Existing Content (Automated Check)
The step to check for existing assets or content that can be reused, is managed via a Work Management System and:
Is automatically generated at the appropriate time
Has to be completed before the process can continue to the next step
Level:
Advanced
Potential solution(s):
Compliance Briefing
Work Management System
Digital Asset Management System
No. 10 - Compliance Briefing
The plan includes a step for producing a “compliance briefing”
Level:
Standard
Advanced
Potential solution(s):
Compliance Briefing
Work Management System
No. 11 - Compliance Briefing (Automated Generation)
The step to produce a “compliance briefing” is managed via a Work Management System and:
Is automatically generated at the appropriate time
Has to be completed before the process can continue to the next step
Level:
Advanced
Potential solution(s):
Compliance Briefing
Work Management System
No. 12 - Compliance Check (Pre Approval)
The plan includes a mandatory step for checking the content before it is submitted for approval
Level:
Standard
Advanced
Potential solution(s):
Compliance Checking System
Work Management System
No. 13 - Automated Compliance Check (Pre Approval)
The step to “check the content is compliant” is managed via a Work Management System and:
Is automatically generated at the appropriate time
Has to be completed before the process can continue to the next step
Level:
Advanced
Potential solution(s):
Compliance Checking System
Work Management System
We will be happy to email you a full version of this Guide (in PDF format)
Benefits of Achieving Best Practice
Overall, achieving content compliance best practice for the Planning and Briefing activity is likely to:
Reduce the risk of Marketing wasting money on a) purchasing assets or b) using 3rd parties to create content, that is not compliant
Increase the % of cases that pass the approval process 1st time around and therefore, minimising:
The amount of content that has to be reworked
The overall elapsed time need to get content approved
Eliminate or minimise the time and effort required by both Marketing and Compliance
Maximise the likelihood that any content that is produced, will be compliant and therefore, will pass the approval process with no or very little amendment / rework
The tables below, give a high-level view of the type and scale of benefits that can be typically realised by achieving a best practice position.
Note. The scale of benefits to be achieved, will depend on:
How far the current way of working is from the best practice way of working
Which level of best practice is achieved – Standard or Advanced
Standard Level
Advanced Level
Do You Have Best Practice?
The following are common indicators that best practice is NOT in place:
Plans are not produced or if they are produced, are not followed
Plans are not available (or not easily available) to all of the people involved in completing the activities / tasks
Briefings do not include information about the compliance requirements
Little or no existing assets or content are reused because:
It is difficult to find them
Marketing always prefer to produce new ones
More than 10% of content fails the approval process 1st time around
Content often has to go through multiple approval cycles before it is finally approved
The time taken to get content approved often causes target dates – for publishing / distribution – to be missed
Marketing often mark their approval requests to Compliance as urgent
If your organisation has any of the above, then it is likely that you are not operating to best practice.
We can help you to:
Define what best practice is appropriate for your organisation
Identify and quantify the benefits that will be realised by achieving best practice
Identify the solution(s) that will enable you to achieve that best practice
Build the business case for any investment that is needed
If you would like to find out more about how we can help ...
Other Activities
Click on the buttons below to view our best practice guides for the other activities involved in the creation of new financial promotion content.
Disclaimer
The information is this guide represents Athena's views based on our experience and also based on input that we have received from a range of different people involved in both creating and approving financial promotion material.
We welcome any thoughts or suggestions regarding:
What "best practice" is or isn't
How best to achieve "best practice"
Anything that you would like to be included in the guide
Copyright Athena Know-How Ltd 2025
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