Resourcing the demands of financial promotions.
In many marketing teams, the marketers responsible for producing materials or financial promotions have the added responsibility of identifying and managing risk, as part of their accountability for achieving their objectives. In other words, applying risk and control measures when producing marketing materials or any other form of communications for clients is built into marketing teams' annual objectives and performance reviews, as best practice within the function.
They should, therefore, have the necessary knowledge, skills and information to produce relevant content that is not misleading and is aligned with the principles set out by the regulator. This requires an understanding of the industry, regulation in the relevant jurisdiction, the company, its objectives, the environment in which it operates and the risks it could face.
For marketing managers performing self-compliance, there are greater demands on governance, as well as in deciding how the regulation is interpreted within the context of specific marketing materials. It’s also important to note that regulations vary across regions, meaning that self-compliance is more feasible in the UK and Europe than in Asia and the US.
Outside the US, the marketing department bears a greater degree of responsibility for financial promotions. This approach works best when dedicated, embedded resources sit in marketing and function as the first line of defence. For smaller groups that do not have a dedicated compliance team, all compliance is integrated into the marketing manager’s role, which risks a resourcing bottleneck for marketing teams. For groups applying a ‘first line of defence’ model, self-compliance exists for low-risk items such as event invitations in a bid to drive efficiency. For others adopting a ‘second line of defence’ approach, a peer review is conducted within marketing and ultimately compliance provides final approval, all managed through a workflow tool. In many instances, this process is still very much owned by compliance.
While approaches to compliance within the marketing function vary, one common thread is the adoption of technology and workflow tools that have simplified the process for marketing teams. Workflow and publishing tools operate in conjunction with each other and drive efficiencies throughout the process, improving collaboration between marketing and compliance functions, and allowing for robust recording and monitoring. Disclaimer templates, for example, can all be stored centrally so it’s clear which disclaimers to use for a specific country, product and audience, simplifying the process for marketers. The correct level of resourcing is still necessary to meet the demand, but the process is simplified and therefore the amount of time required is reduced.
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