MARKETING CORRESPONDENCE REVIEW

One platform for content compliance

A centralized place to maintain the proposed and approved communication materials, as well as track the approval process.
Manage all proposed marketing communications, including social media posts, in one platform.
Track reviews, approvals, and discussions with an easy-to-use workflow.
Maintain a complete, exportable audit trail for FINRA submissions.

Relevant rules

Addresses FINRA Rule 2210(d), which requires broker-dealers to document its review and approval of correspondence, such as marketing materials, for appropriate content standards.

Common deficiencies

Failure to have a system that reviews and retains marketing materials (including social media communications) and document reviews and approvals of content standards.

Knowtice’s prevention plan

Knowtice’s platform provides for a centralized place to both maintain the proposed and approved communication materials as well as track the entirety of the approval process, including discussions between the parties that propose and approve the communicated materials.
Key features:
A crowdfunded guidance tool based on actual communication comments from FINRA’s ADV department.
Key features:
An exportable audit trail to simplify submission of approval tracking.
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Real findings. Real fines

Recent fines of broker-dealers highlight the necessity of utilizing a system to track, review and document the basis for approvals of marketing materials.
Broker-Dealers Fine
Date
May 2025
Broker-Dealer
BTG Pactual US Capital
Fine Amount
$400,000
Failure to establish and implement AML processes that could detect suspicious transactions.
Fine Amount
$350,000
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Date
May 2025

Paying influencers to promote, whereby statements were made that were not fair and balanced or made claims that were misleading or unwarranted.

Fine Amount
$1,600,000
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Date
May 2025
Broker-Dealer
Webull Financial

Failure to reasonably supervise or retain social media communications promoting the firm.

Fine Amount
$26,000,000
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Date
February 2025

Failure to retain and supervise social media communications promoting the firm that were posted by paid social media influencers, some of which were promissory or not fair and balanced.

Fine Amount
$300,000
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Date
January 2025
Broker-Dealer
Avenue Securities

Failure to maintain a system to supervise social media communications disseminated by influencers.

Fine Amount
$750,000
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Date
November 2025

Failure to maintain a system to supervise influencers’ retail communications and preserve records thereof.

Fine Amount
$250,000
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Date
June 2024

Failure to maintain a system to review and approve influencer communications to ensure that such were fair and balanced or did not include included exaggerated and promissory statements.

Fine Amount
$200,000
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Date
April 2024
Broker-Dealer
Cobra Trading, Inc.

Failure to maintain a system to supervise influencers for promotional communications on social media platforms, including online interactive forums and video sharing platforms.

Fine Amount
$850,000
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Date
March 2024
Broker-Dealer
Cobra Trading, Inc.

Failure to supervise social media posts made by influencers that were not fair or balanced, or contained exaggerated, unwarranted, promissory or misleading claims.

Use our Marketing Correspondence Review to prevent costly fines!

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