Compliance expert Cindi Hill very kindly reviewed the compliance section of my Financial Blogging book from the perspective of a registered investment advisor (RIA). I’m delighted to share her guest post on compliance and your blog. It seems to me that most of her advice also applies to other forms of advisor writing that might be considered marketing or advertising.
Top 3 Compliance Concerns When Writing Your Blog
By Cindi R. Hill
Let’s explore the compliance side of writing your blog. What are the things you should avoid or be concerned about when planning what you will write in your blog?
1. Understand who will need to review your blog
Is it simply the chief compliance officer or will your blog post need to go through a complete review cycle? How much lead time is needed for the review? If you have something that includes breaking news, you don’t want it tied up in review for days. In some states, like Idaho, all advertising items are required to be reviewed and approved by the state prior to being published.
2. Learn the guidelines for discussing performance
If you discuss investment performance, you need to follow guidelines. There are disclosures that may be required as part of your blog footer, the text that runs immediately under the body of each post. Which guidelines and disclosures depends on if you are registered with the SEC, your state, or FINRA. Be aware of these before you start to write.
3. Use words carefully
When reviewing any advertising/marketing piece I look at the words used. Some I discourage from use are “no bias” or “no conflicts of interest.” Just because you are a fee-only advisor does not mean that you have no biases.
This leads me to other types of words you should avoid, starting with definitive descriptors like “all” or “will.” Use “may” when you are tempted to use “will.” On a similar note, the word “exact” in a blog will get my immediate attention.
Another type of word I suggest staying away from—adjectives. For example, “excellent” or “superior” when referring to returns. This may seem obvious, but I have had to remove them from a reviewed document in the past. Also “highly” as in highly experienced. Or another one: “ultra-low cost.” You get the picture.
Remember that your blog is an advertisement. Compliance around any advertisement applies to your blog. No testimonials. This prohibition appears to apply to non-investment advisory activities as well.
Cindi R. Hill, CFP®, IACCPTM of Hill Compliance Advisors provides comprehensive compliance services and solutions for the financial professional who is a Registered Financial Advisor (RIA). You can follow her blog at https://hilladvisors.wordpress.com.