Raise your hand if you just love the process of getting review documents signed off so your firm can get advertising materials out into the market.
Since it’s fairly certain no one out there is currently raising their hands, we can probably agree the review process is a necessary annoyance at best, and a serious frustration at worst.
We’ve put together a list of some of the top headaches clients mention when it comes to the advertising compliance review process. If any of these sound familiar, you can take comfort in the fact that you’re not alone, and that there are solutions many firms are using to make these processes a little easier and less fraught, while still maintaining a high standard of compliance.
What are the top headaches in the advertising compliance review process, according to compliance professionals and marketers?
1. Keeping track of paper documents.
Many marketing teams like to have hard copy paper signoffs from their reviewers, so they can say, “This is what this document looked like at this point in time, and here’s the official endorsement.”
As more people and workplaces transition to remote work, though, doing paper copy reviews can become almost impossible. You either end up with tremendous lag times because people are shuffling physical files back and forth, or you have to deal with grainy documents from scans, or with multiple digital copies and email chains.
All these scenarios create a definite headache in the short term, as well as an even more frustrating headache when audit time comes. Instead of managing paper, firms should look for tech solutions to make the advertising compliance review process less cumbersome; in fact, it’s becoming an expectation from regulators that teams will have technology solutions to manage and document their compliance processes.
2. Maintaining an audit trail.
Paper processing makes building your audit trail tricky. Instead of being able to show a clear timeline and a narrative that backs up your commitment to compliance, you may find while lining up paper files in advance of an audit, your process looks rather disjointed.
If you have a lot of reviewers involved, for example, there may be multiple paper copies with conflicting suggestions. You’d have to think long and hard to determine why certain choices were made and why one option was selected over another.
Organizing all these pieces and forming a narrative for your auditors can be time-consuming. It can also make it seem like you’re not doing everything you can to streamline processes, because of the sheer enormity of paper documentation you’re asking your auditors to review.
A cloud-based audit trail provides the best solution, as it’s not dependent on people being in a shared location or on a shared network. And, it’s accessible to everyone during periods where companies may need to have teams work from home because of circumstances outside their control.
Managing advertising compliance review with manual systems can lead to a lot of confusion and miscommunication. People can easily forget what they were asked to manage or lose track of a proofreading/approval sheet amid the clutter of the average busy person’s desk.
When there’s no tool in place to keep everyone in line, honest misunderstandings can happen and can corrupt trusting working relationships.
These types of miscommunications can occur in both remote and in-person work. In-person, people may feel comfortable discussing materials in a hallway conversation, but those comments may never be suitably incorporated into the final review or properly documented in the process. Remotely, miscommunication can occur if people are conducting most of their conversations by email or tagging some review comments on to the end of a Zoom call.
The best way to avoid miscommunications is to have strong working relationships and stronger processes and procedures. And, to back that up, it’s extremely important to have a single source of truth for disclosure messaging, one source location for information, adding notes/comments/annotations. By combining these two forces together, miscommunications can be greatly reduced and made less inconvenient.
4. Missed deadlines.
Time flies when you’re having fun. And, it also, unfortunately, can fly when you’re not necessarily having fun but are instead just really, really busy.
One of the biggest headaches in the compliance process is trying to squeeze reviews into an already packed schedule. No one wants to miss deadlines, and not hitting a release or launch date can create a lot of trouble, frustration, and animosity between teams.
As a compliance professional, if you have a big project that’s on deadline, or if you’re trying to prepare for auditors to come in, you probably have good intentions to get to every advertising review on time. However, those other responsibilities can’t wait either – and telling your boss you weren’t prepared for an audit because of marketing reviews probably isn’t going to fly.
At the same time, marketers are juggling a lot of moving pieces as try to launch their own initiatives to support the business. They’re also under pressure and realizing their campaign can’t roll out because they skipped a step in the compliance review/approval process – that’s also a big headache.
To improve, get everything on paper, or better yet, online. Automate processes, so you’re not relying on a manually set calendar reminder or a hastily scribbled sticky note to remind you to handle your part in the process.
Let’s face it – sometimes the stereotypes of each department’s role in the compliance process can have a little truth to them. You’ve probably heard:
- The marketers want their collateral to “look pretty” and want to keep graphics and attention-catching headlines front and center. They don’t have any room for bulky disclosures that distract.
- The compliance team wants to ensure every t is crossed and every i is dotted, so there’s no potential for risk to come back and haunt the firm.
In reality, both sides are looking for the same thing – risk mitigation that supports the firm’s goals. They may just express their desires in different ways.
Those different expressions are the problem, as they can lead to disagreements and stand-offs over content and disclosures. It’s much easier to reduce disagreements when your teams have tools in place that clearly outline proper usage of disclosure content. It reduces the need to argue back and forth over substance because both teams have a stronger understanding of what’s required before you get down to the wire on getting something out.
6. Missed steps.
As mentioned earlier, the recent expansion of remote work is changing up many companies’ processes and policies. It stands to reason that steps will be missed because new steps are also – whether purposefully or inadvertently – being added.
Missed steps in the review process can be a tremendous headache for many reasons:
- It opens the firm up to audit risk if there are clearly defined policies that aren’t being followed because of disorganization or lack of time.
- It can push back release dates or launches that affect the marketing team’s ability to strategically position the firm and to compete.
- It creates additional work for the compliance officer who needs to review the final piece. If a step is missed in the process, regardless of whether the compliance officer was connected to the misstep, they will still have to take time to complete another review and provide a stamp of approval, which takes time away from other strategic efforts.
What’s the best way to deal with missed steps? Proactive collaboration.
Work together ahead of time to create a workflow that fits everyone’s needs, then move items through the process. If anything’s missed along the way, it should be very noticeable. This type of process management can also stand you in good stead when audit season rolls around.
7. Too many chefs.
When creating content, the marketing team will have likely several people in their area go through collateral and complete a thorough review. The compliance officer will review as well. Add in business unit leaders and product managers who want to see the piece, and you’ve got a lot of hands meddling with and weighing in on advertising compliance reviews.
58 percent of marketers say their projects go through five or more rounds of review. In a shocking 14 percent of cases, documents complete more than 10 rounds of a review!
That’s a lot of time and resources that are being invested into a piece of collateral. And, when many people are reviewing the same document, the review process can often veer from the straight and narrow, from weighing in specifically on an area of expertise to critiquing artwork, disclosure placement, and more.
When such a large group of people becomes involved, it slows down the process and widens the margin of error because of the increased number of documents floating around.
Boomeranging work can create frustration and confusion, and engender a lack of clarity and confidence in the final product. And, of course, when multiple opinions are involved, it leads to some of the other headaches we’ve discussed in this article – like missed steps, unclear roles, and messy audit trails.
Again, creating workflows and employing technology can be very helpful in this process. Oftentimes, additional review cycles are added because the people managing it don’t have confidence in their process.
Building a flow and making sure everyone’s onboard can reduce the concerns of team members and managers/leaders. This proactive effort creates the potential to reduce actual reviewers to just the folks who need to be involved, instead of adding in a herd of micromanagers and slowing down the process.
8. Unclear roles.
Who has the final say on content topics versus what the final format looks like? Which senior leaders at your firm need to sign off for approval, versus just being aware of the marketing pieces that are about to be distributed?
When team members don’t have clarity about their role in the review process, it can lead to disputes, hurt feelings, and animosity. When you’re distributing information for review, consider using a RACI chart to let people know their roles – whether they’re intended to be a responsible party, an accountable party, a consulted party, or an informed party.
When people know their roles, they’re more likely to either step back and observe or take a proactive approach – depending on their specific area of responsibility.
Compliance, particularly advertising compliance, doesn’t have to be a headache. To make it less cumbersome and more of a valuable, strategic benefit, teams need to develop the right processes, use the right tools and build the right relationships. With those systems in place, compliance teams, and their counterparts in marketing and operations, will be able to do their jobs faster and more effectively.
About Red Oak Compliance Solutions
Red Oak Compliance Solutions is the global advertising review software of choice in the financial services industry, serving clients with more than $19 trillion in assets under management. Red Oak’s advertising compliance review software offers quick implementation timelines, as well as agile technology that responds to client needs and is 100% Books and Records compliant. Our clients report 35% faster approvals and 70% fewer touches, with many experiencing even better results. Are you ready to minimize risk, reduce costs, and improve efficiency? Contact the Red Oak team to learn how.
About Red Oak Compliance Solutions
Red Oak Compliance Solutions is the global advertising review software of choice in the financial services industry. It is a comprehensive suite of SEC 17A-4 compliant features that are 100% books and records compliant and provides clients with 35% faster approvals and 70% fewer touches or better. We also offer Smart Review(SM), which solves for the storage and maintenance of disclosures, helping firms reduce risk, decrease review times, and increase the speed of distribution of marketing materials. Smart Registration(SM) automates the licensing and registration management process to help reduce regulatory risk and time spent on manual processes. Overall, Red Oak allows firms to minimize risk, reduce costs, and increase compliance review process effectiveness and efficiencies.