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SD-15.6 — Marketing-Material & Financial-Promotion Approval

Business Domain: BD-15 Distribution, Product & Client Management (Commercial) · Applies: BOTH

Purpose

Reviews and approves all client-facing promotional material before it is issued — the operational pre-issue control that keeps the firm’s marketing fair, clear and not misleading, and compliant with the financial-promotion regime. SD-15.6 is a control capability: every piece of marketing material, every financial promotion, every pitch document passes through its review and sign-off. It exists because a financial promotion is regulated speech — the SEC Marketing Rule and the FCA financial-promotion rules hold the firm answerable for every claim and every performance figure. It is not the production of the material — that is SD-15.5 and SD-15.7. It is not investment compliance, BD-10 — BD-10 monitors the portfolio, SD-15.6 monitors the outgoing communications. And it is not the firm’s CCO function — that is SD-14.2 Corporate Compliance & Conduct, which sets the conduct-compliance standard SD-15.6 applies on every specific item. The Marketing Review Committee (or equivalent body) — typically compliance-staffed but operationally embedded in the distribution flow — is SD-15.6’s; the CCO and the regulator-facing compliance programme are SD-14.2’s. SD-15.6 sits in BD-15 because the capability runs operationally inside the distribution workflow.

Service Operations

  • Review promotional material — review every client-facing marketing and promotional item against the financial-promotion rules.
  • Approve and sign off — approve, reject or require changes to promotional material, and record the sign-off.
  • Govern performance and claims presentation — check that performance, track-record and comparative claims are fair, balanced and compliant (the SEC Marketing Rule’s performance-advertising requirements).
  • Maintain the promotion register — maintain the register of approved promotions and their review trail.
  • Manage the approval standards — maintain the firm’s standards and templates for compliant promotional material.

Inputs and outputs

  • Inputs: draft marketing and promotional material from SD-15.5, SD-15.7 and SD-15.8; the financial-promotion regulation; performance data from BD-09.
  • Outputs: approved promotional material and the promotion register — consumed by SD-15.5 / SD-15.7 (cleared to issue) and SD-14.2 / SD-14.8 (the compliance and audit evidence).

Entities

  • Consumes: the marketing material and the performance records; the SD-15.5 draft marketing and promotional material; the SD-15.7 draft marketing and promotional material; the SD-15.8 draft marketing and promotional material.
  • Owns: the promotion-approval register — a process artefact.

Standards

  • The SEC Marketing Rule (Rule 206(4)-1) — including the performance-advertising requirements.
  • The FCA financial-promotion rules (COBS 4).
  • The UCITS / PRIIPs marketing-communication requirements and the cross-border pre-marketing rules.

Open extensions

  • The approval-workflow sub-model.
  • The performance-claims sub-model.
  • The Service-Operation-level input/output contracts.

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