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Advertising Review: Is Your Marketing Collateral Review Process 17a-4 Compliant

Is Your Marketing Collateral Review Process 17a-4 Compliant?

RegEd’s Advertising Review solution is built to support firm’s marketing collateral approval process. In addition to robust workflows, Advertising Review is designed with compliance in mind including Worm and D3P support per SEC requirements.

Many regulations imposed by FINRA and the SEC have to do with the archiving of electronically stored information (ESI). Therefore, to ensure compliance firms are required to archive all necessary ESI. However, just archiving the data is not enough. SEC Rule 17a-4 mandates it must be archived in the proper format to meet compliance standards.

Write Once Read Many (WORM)

WORM describes a data storage device in which information, once written, cannot be modified, overwritten or deleted. This write protection affords the assurance that the data cannot be tampered with once it is written to the device.

The SEC defines which books and records to WORM such as purchase and sale documents, customer records, associated person records, customer complaints, and certain other matters. Additionally Rule 17a-3 and Rule 17a-4 specify minimum requirements with respect to these records that broker-dealers must make, and how long those records and other documents must be kept. 

Designated Third Party (D3P)

Broker-Dealers are required to have at least one Designated Third Party (D3P) Compliance Provider for each electronic records archive. RegEd’s D3P service bridges the compliance gap.

D3Ps agree that in the event of the failure or inability of the Broker-Dealer to download requested records, they will undertake that effort to provide to the requesting regulatory or legal body. As your designated D3P provider, RegEd will take the lead on providing the records it holds for you as your WORM storage provider and supply them to regulators if you cannot do so.

Penalties for Non-Compliance

It’s concerning how many firms fall into non-compliance with existing regulations. FINRA is becoming more and more focused on imposing fines and penalties. In 2017 FINRA fined 12 firms for a total of $14.4 million for, “…significant deficiencies relating to the preservation of broker-dealer and customer records in a format that prevents alteration.”

In a statement about the sanctions, the SEC pointed to the importance of record keeping in protecting investors, saying that records are the “primary means of monitoring compliance with applicable securities laws, including anti-fraud provisions and financial responsibility standards.” FINRA further explains how WORM storage is critical due to the increased volume of sensitive data being stored electronically.

WORM Compliance with Advertising Review

RegEd offers a robust, scalable, and configurable WORM storage solution that enables firms to fulfill their books and records obligations.

RegEd’s Advertising Review WORM storage device offers the ability to automate retention events and periods based upon workflow configuration within the application to ensure your data is captured at the required points of submission, revision and approval. Once deployed with your firm, no additional steps must be taken to ensure your data is sent to the WORM storage device with its appropriate metadata and attachments. 

Even if your firm’s marketing team uses a different front-end to create content, Advertising Review can easily integrate with APIs to automatically push content to the compliance review process where final approved files can be properly stored in a WORM compliant format.

Stay Compliant

Using a product like RegEd’s Advertising Review ensures firms interweave compliance within their processes. Compliance is always more cost effective & protective of your business reputation than alternative fines and sanctions. Firms that research, understand, and apply best practices in their marketing collateral review process avoid negative publicity and profit-loss.

Advertising Review: 4 Ways to get the Most From Your-Reports

4 Ways to get the Most From Your Reports

Reports show trends on how well your firm did in the past, as well as what’s coming down the pike. These are key factors that drive success for the firm. Information provided by reports is especially important in today’s compliance environment, where it’s critical to be proactive instead of reactive.

To make the most of RegEd’s Advertising Review reporting capabilities, follow these proven steps to improve your process.

1. Determine what's important to your firm

Executives consider reporting vital to find answers to questions regarding their business.

Start by asking questions at the top. When prototyping your reports, it’s important to first define what executives (especially your CCO and CEO) want to see. Are they concerned about turnaround time or just general data regarding the advertising review compliance process? What are their key metrics? What behaviors do they want to encourage or discourage?

Align with your team’s vision. Take your business goals and map those metrics to the capabilities of Advertising Review reports. For example, if the firm wants to know how long a certain item takes to be reviewed, pull the turnaround time report. Or use the Search All Requests tool to create custom reports based on a variety of metrics – including timeframes, standard metadata fields, FINRA-specific fields, and custom metadata fields.

2. Capture the right data

Your reports are only as good as the data behind them. Planning and setup are the keys to capturing the right metrics. The RegEd implementation process takes data in to consideration during the workflow creation process, but sometimes years have passed since a firm has reviewed their setup. If you’re just about to start an implementation, be sure to look at your custom fields and configurations to see if it will provide the reports you want. If your workflow is well established, it may be a good time to audit your process to find ways to optimize. In either event, we suggest working backwards – plan your reports first and then configure the application accordingly.

Keep your scope focused and only measure what matters. Pick a limited number of key performance indicators and metrics. A third-party survey of the number of metrics used by CEO’s showed that over half use only 5–10 metrics to manage their entire firm. It is also a good idea to limit the number of reports. Focus on those tied to specific business objectives.

3. Create your reports

Most firms start with existing reports from previous applications or processes as a baseline. As you begin to build workflows, and subsequently your reports in Advertising Review, there are several resources to help you get started.

Begin with standard reports. Advertising Review offers standard reports across all versions. See the following standard the filtering options. Note that not all reports have the same filtering options.

  • Completion Date: Allows for filtering based on date values (YTD, Last 12 months, etc.). Use this to target important data.
  • Grouping Options: How should reports be grouped? This filter will be report-specific and could include status, originator, branch, and/or format.
  • Rep Attributes: Filter by up to four (4) different rep attributes such as title, position, or hire date (as well as many more).

Next take a look at the Search All Requests reports tool. This allows you to create ad hoc reports using over 25 standard metrics as well as any custom metadata fields in your workflows. Configure, save, export, and repeat as often as needed. Don't reinvent the wheel! Talk with your Relationship Manager to see what other firms have implemented and learn more about best practices so that you and your team are working with data that helps you make more informed decisions.

4. Use data to drive behavior and produce results

Reports are designed to be iterative, it’s important to keep them current and relevant. To successfully roll out business metrics, good communication is key. Use the My Reports feature to easily find your favorite reports.

Manage from the top down. Encourage managers to run meetings directly from their reports. Many customers also have the following mandate for compliance and marketing: “If it’s not in Ad Review, then it doesn’t exist.” This directive proves to be extremely motivating for teams.

Finally, engage your user community. Don’t make the mistake of tracking metrics only at the executive level, make sure your users can access the reports that are important to them. What do your users want to see? What will help them do their jobs faster and smarter? Those are the metrics that matter.

Efficiencies with Advertising Review’s Two-Way FINRA Integration

Efficiencies with Advertising Review's Two-Way FINRA Integration

Firms filing their advertisements with FINRA know how time consuming and cumbersome the process can be. Not only does the firm need to review collateral based on internal processes, but they also need to organize and send firm-approved files to FINRA based on FINRA 2210. FINRA offers two ways to initiate the review process – either manually through their web portal, or by integrating with its Advertising Review Electronic Files (AREF) system.

Since AREF was introduced with RegEd’s Advertising Review solution in 2010, firms had the ability to automate the sending process. As of the spring 2018 release, firms can now take advantage of full automation with our two-way integration – send and receive FINRA results, and automatically WORM content (for firms that have RegEd WORM enabled on their workflows). The enhancement provides a holistic solution for end-to-end FINRA filing support. See the following three most exciting features included with Advertising Review’s AREF integration.

Two-Way Integration

Use the built-in AREF integration to send content to FINRA and receive notifications when the status and letter are returned. We’ve done away with waiting or having to manually check FINRA’s portal to see if a decision was made. Advertising Review’s AREF integration takes care of that for you. Not only does it automatically WORM the content (when enabled), it retrieves the status and letter when a decision is made, and notifies the applicable user(s) by email.

FINRA AREF 1

Effortlessly Manage Multiple Filings per Submission

What happens if a file is returned with a status other than ‘OK’ or ‘LIMITED’? How can you track the progress of updating the collateral and resubmitting to FINRA? That’s easy with Advertising Review’s history log. Directly in the submissions, users can view the snapshot of FINRA correspondence. Then with a few clicks, users can dive deeper to view individual filings, fee estimates, current status, and more.

FINRA AREF 2

Actionable & Accurate Reporting

Due to FINRA’s 2210 requirements, it is important that firms adhere to the rule to avoid being penalized. One way RegEd’s Advertising Review solution makes this easier is with the dedicated FINRA report. In addition to metadata directly related to FINRA filings, the export includes result details, status information (including applicable dates), fee amounts, as well as any Additional Documentation notes included with the submission. The report provides firms the power and flexibility to mitigate or eliminate gaps in their FINRA filing process.

FINRA AREF

Not using RegEd’s Advertising Review solution? Contact sales@reged.com or 888.334.8322 today!

Already using RegEd’s Advertising Review solution but not AREF? Contact your Relationship Manager today to learn how to add it to your subscription.

The Future of Customer Communications Compliance

The Future of Customer Communications Compliance

We had a blast during the 2018 Advertising Review Client Advisory Board (CAB) meeting! A dozen of our clients and RegEd employees teamed up to review what’s coming down the pike for RegEd’s Advertising Review solution and the industry. During our nearly two-hour meeting, we discussed product features, played innovation games, and explored what the future of the industry could look like. See below for the top takeaways from this year’s session.

Third-Party Integrations

Over the past few years it has become more important than ever to have a fully holistic up- and down-stream review process. This includes connections with Marketing teams, Legal, and Subject Matter Experts (SME). Advertising Review has supported end-to-end compliance since its inception nearly 15 years ago – including integration with internal marketing and legal processes. However, firms are beginning to use a multitude of different software packages within the organization to satisfy siloed needs.

In 2016 Advertising Review started to bridge this gap when it released API web service integrations to allow different software to effortlessly communicate with Advertising Review. Several clients took advantage of this benefit by integrating internal systems, but we continued to receive requests to have turn-key connections with the most popular platforms used by other business groups in their organizations.

We were happy to announce during the CAB that we are indeed working throughout 2018 and 2019 to create “connectors” with other popular software products. Though we are not able to discuss details publicly at this time, please reach out to your Relationship Manager to provide feedback and suggested platforms to integrate with. If it is one we are currently working with, we will be sure to incorporate your ideas and recommendations.

Updated Reporting Metrics

It was clear that firms are consuming more and more data to help make better decisions throughout the compliance lifecycle. In doing so, it is vital that firms have access to reports to make their jobs more efficient. Advertising Review has always had actionable standard reports, and added the Search All Requests ad-hoc reporting tool in 2015.

The CAB members were given an opportunity to highlight other features they would like to see added to report functionality. In general, users would like to see additional filter metrics within the Search All Requests tool – mostly around attributes. CAB members went on to explain that using Rep Attributes that are fed into the RegEd system will help further refine their reports, such as submitter parameters like organizational status or individual distinctions.

The Advertising Review team is currently reviewing the specifications for an upcoming release. If you have any other report-specific suggestions, please reach out to your Relationship Manager.

Artificial Regulatory Intelligence

Artificial Intelligence (AI) has been a buzz word that continues to float around the regulatory industry. Many have a hard time categorizing or articulating what it is and how it should intersect with the compliance industry. Without going into too much detail, it is important to have a general understanding of the concepts. There are essentially two types of AI: Narrow and General. Narrow is what most of us are aware of – Siri, Alexa, Spotify, Amazon Shopping suggestions, etc., – which are really good at one or two processes. While General AI is the belief that machines can function like a human brain and is very good at a multitude of actions, including learning.

After understanding the general definition of AI, most in the industry agree that Narrow AI is what will help streamline firm operations. The Advertising Review team is targeting a future release of an initial Artificial (Narrow) Intelligence feature. If you would like to collaborate on the process, please reach out to your Relationship Manager.

Excitement for 2018

Most of what is covered during CAB meetings are long-term goals, however, we also discussed what is coming in 2018. We have several exciting features including three large enhancements this year:

AREF 2.0: Two-way integration with FINRA’s AREF system. Letters and statuses are automatically ported back in to Advertising Review.

Expiration Extension: Ability to extend the life of a review item without having to copy, clone, or resubmit a submission.

All-New User Interface: Completely redesigned the user interface to improve the user experience by reducing number of clicks and creating a fully-responsive application on desktops, tablets, and mobile devices.

We’re excited about the future of Advertising Review and appreciate our client’s commitment to partner with us today and in the future. For more information, please continue to subscribe to our Did You Know emails and check for upcoming webinars and whitepapers.

Not using RegEd’s Advertising Review solution? Contact sales@reged.com or 888.334.8322 today!

Already using RegEd’s Advertising Review solution but not AREF? Contact your Relationship Manager today to learn how to add it to your subscription.

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