Marketing and client communications reviewed against the marketing rule, before they go out and after.
Bluegrass builds review systems for RIAs and wealth managers that check advertisements, websites and social posts against the SEC's marketing rule and your policies before use. They also read client communications once sent, explaining each issue for your chief compliance officer to decide.
Compliance teams at advisory firms are small, and marketing has grown with every advisor's website, newsletter and social account, so review either slows marketing or shrinks to a sample.
What marketing and communications review involves today
Under the marketing rule, an advertisement may not contain untrue or unsubstantiated statements and must present performance fairly, with net results beside gross and standard time periods. Testimonials, endorsements and third-party ratings need the disclosures and oversight the rule requires.
Firms must also supervise what their people send clients by email and text, where keyword surveillance raises so many false alerts that real issues are easy to miss. Both are reading problems suited to a language model, with the compliance officer deciding every finding.
How automated marketing review works
- 01
Collect what needs review
Drafts come from marketing and advisors, and websites, social accounts and sent communications are gathered from your archive, so review covers what is actually published and sent.
- 02
Check against the rule and your policy
Each piece is read against the marketing rule and your written policies, covering the substantiation of claims, the presentation of performance, testimonials and endorsements, third-party ratings and required disclosures.
- 03
Explain each issue
Every issue is listed with its passage, the requirement it relates to and a suggested change, so the reviewer can decide quickly and the author knows what to fix.
- 04
Supervise communications
Client messages are read in context for what your supervision procedures need to see, such as promises of returns, complaints or a move to an unapproved channel.
- 05
Keep the record
Each review, decision and approved version is retained, so the file shows what was reviewed, by whom and when, as an examiner will expect.
Where people stay in the loop
Your chief compliance officer decides every finding and approves every piece, and the system's reviews are first compared with your team's own on past material. The requirements it checks are agreed with your compliance team and counsel.
The systems it works with
The system works with your existing archiving and supervision platform, website, social accounts and CRM, and records each review and approval where your books and records policy requires.
When to build it, and when to buy it
Archiving, supervision and marketing review tools for advisors are established, and several now use AI to flag issues. If your needs are standard, switching that feature on may serve you well.
A custom build makes sense when your policies go beyond the rule, when review must cover advertisements, communications and your website together, or when you also operate a broker-dealer and the same material must meet FINRA's communications rule.
We hold no reseller agreements, partner quotas or revenue share with any vendor, so a recommendation to buy is made on its merits.
What this work costs you today
A quick way to put a number on the problem before talking to anyone, using your own figures rather than ours.
Enter your volume and the minutes each one takes to see what the work costs in a year.
The numbers stay in your browser and are not stored or sent anywhere. Bring the figure to the first call, since it is the baseline any system should be measured against.
Questions about marketing and communications review
- Can it check performance presentations?
- It checks that gross performance is shown with net, that the required time periods are present and that hypothetical or extracted performance carries what your policy requires. Anything it can't verify against your records is flagged for the compliance officer.
- Does it replace our archiving system?
- It works alongside the archive, reading what it holds and recording reviews there, so your retention and supervision records stay where they are.
- Does it work for dually registered firms?
- Material that must meet both the SEC's marketing rule and FINRA's communications rule can be checked against both in one review, with each finding labeled by its rule.
Related systems
A senior team that has done this before
We are a small, entirely senior team with fifty years of combined AI engineering, multiple granted patents and Y Combinator founders, from Yale, MIT, McKinsey, Goldman Sachs, Microsoft and Vista Equity Partners. The people who scope your work are the people who write the code.
Selected work
We built the AI transformation roadmap for a top-50 P&C brokerage, and it is saving the firm millions of dollars in vendor fees it did not need to pay.
Clients include some of the largest banks, RIAs, fintechs and AI labs, as well as a top-3 P&C carrier, a top-10 P&C brokerage, a top-5 trucking brokerage, a leading specialty MGA and a leading trucking MGA.
We run only 3 to 5 engagements at a time, so that every client works directly with the senior team.
About the team- Dozens
- of insurance companies, RIAs, banks and fintechs we have worked with
- 50 yrs
- combined AI engineering experience
- 10+ Patents
- granted to members of the team
- 100%
- of the IP we build is assigned to you
Find out whether this is worth building for your business.
A 30-minute call with an engineer usually shows whether this is worth building. Within a week you will have a free written point of view, including whether a packaged product would serve you better.