FINRA Communication Supervision and Approval Standards

To meet the finra communication supervision and approval standards requirement, you must supervise, review, and (for many retail communications) obtain qualified principal approval before use, and you must prevent false, misleading, or materially incomplete statements in any business communication. Build written supervisory procedures (WSPs), route content through documented review workflows, and retain evidence that supports claims and approvals. (FINRA Rule 2210, FINRA Rule 3110)

Key takeaways:

• Classify every channel (retail communications, correspondence, institutional) and apply the correct review/approval path. (FINRA Rule 2210)
• Require documented principal approval before first use for in-scope retail communications, with clear escalation for higher-risk content. (FINRA Rule 2210)
• Keep “claim support” files and supervision records that show what was sent, who approved it, and why it was not misleading. (FINRA Rule 2210, FINRA Rule 3110)

FINRA expects member broker-dealers to control what they say to the public with the same discipline they apply to trading, suitability, and sales practice supervision. “Communication” is not just glossy marketing. It includes emails, letters, website pages, blog posts, social media posts and comments, videos, pitch decks, market updates, and any other business message that could influence a retail investor’s understanding of your firm, products, or services. (FINRA Rule 2210)

Operationally, the requirement comes down to two outcomes: (1) your communications cannot be false, misleading, or omit material facts needed to make the message fair and balanced, and (2) you must have a supervision system that reliably catches problems before (and after) publication. (FINRA Rule 2210, FINRA Rule 3110)

This page is written for a CCO, Compliance Officer, or GRC lead who needs to stand up an executable program quickly: roles and responsibilities, intake and classification, principal approval, claim substantiation, surveillance of outbound channels, recordkeeping, and exam-ready artifacts. Where tooling helps, Daydream can be used to centralize requirements-to-controls mapping and evidence collection so you can prove supervision worked without building a parallel spreadsheet system.

Requirement: FINRA communication supervision and approval standards requirement (Rule 2210 + supervision under Rule 3110)

FINRA’s communications rules require that communications with the public are not false or misleading and do not omit material facts or needed qualifications; they must provide a sound basis for evaluating the facts. (FINRA Rule 2210) You must also supervise your firm’s activities with written procedures and a system reasonably designed to achieve compliance, which is how exam teams evaluate whether your communications program is actually working in practice. (FINRA Rule 3110)

Plain-English interpretation

Your communications program must do three things consistently:

1. Stop misleading content: No untrue statements of material fact; no misleading claims; no missing qualifiers that change the meaning. (FINRA Rule 2210)
2. Control publishing: Don’t let staff post first and “fix later” for in-scope communications. Use pre-review and, where required, principal approval before first use. (FINRA Rule 2210)
3. Prove supervision: Keep records showing the content, the review/approval, and the substantiation for key claims. Your WSPs should explain the workflow and who is responsible. (FINRA Rule 2210, FINRA Rule 3110)

Who it applies to

Entities: FINRA member broker-dealers. (FINRA Rule 2210)

Operational context (where this bites in real life):

• Marketing and growth teams creating campaigns, websites, and social content. (FINRA Rule 2210)
• Registered reps sending emails, texts, DMs, newsletters, seminar invites, and market commentary. (FINRA Rule 2210)
• Product teams publishing product pages, FAQs, and performance-related content. (FINRA Rule 2210)
• Executives posting on social media about offerings, partnerships, or results when it is business-related. (FINRA Rule 2210)
• Third parties creating content “for” you (agencies, affiliates, lead generators) when the content is used by the firm or on the firm’s behalf; you still need supervision controls to prevent misleading statements. (FINRA Rule 3110)

Regulatory text

“No member may make any retail communication or correspondence that contains any untrue statement of a material fact, or is otherwise false or misleading. Communications must provide a sound basis for evaluating the facts and must not omit material facts or qualifications.” (FINRA Rule 2210)

What the operator must do with this text: implement a repeatable process that (a) reviews communications for accuracy and completeness, (b) documents the basis for statements that could be material to a retail investor, and (c) prevents distribution of content that fails the review. (FINRA Rule 2210, FINRA Rule 3110)

What you actually need to do (step-by-step)

1) Build a communications inventory and classification scheme

Create a register of:

• Channels: website, app content, email, social platforms, webinars, events, print, SMS, chat, third-party sites. (FINRA Rule 2210)
• Communication types aligned to FINRA categories: retail communications, correspondence, institutional communications. (FINRA Rule 2210)
• Owners: business owner + compliance reviewer + approving principal. (FINRA Rule 3110)

Output: Communications Channel Matrix (channel → type → required review/approval → archiving method). (FINRA Rule 2210, FINRA Rule 3110)

2) Define review standards that catch “misleading by omission”

Your review checklist should test:

• Accuracy: every factual statement that could influence a customer decision has support. (FINRA Rule 2210)
• Balance: benefits are not presented without material risks, limitations, or conditions. (FINRA Rule 2210)
• Clarity: disclosures are readable and proximate to the claim they qualify (avoid “disclosure dumping” in footers for critical qualifiers). (FINRA Rule 2210)
• Consistency: align with offering materials and current product terms; stale content is a common failure mode. (FINRA Rule 2210)

Practical move: maintain a “standard disclosures library” (risk language, fee statements, product limitations) and require marketing to pull from it rather than drafting from scratch. (FINRA Rule 2210)

3) Implement principal approval gates for in-scope retail communications

Design a workflow where:

• Draft content is submitted with an intake form that captures objective, audience, channel, product references, and material claims. (FINRA Rule 2210)
• Compliance review happens before publication.
• Where required, a registered principal provides documented approval before first use for retail communications. (FINRA Rule 2210)

Control design tip: enforce this with tooling, not reminders. If your CMS/social tool can publish without approval, you don’t have a real gate. (FINRA Rule 3110)

4) Create “claim substantiation” packages (the exam saver)

For each piece of content that includes performance, comparisons, pricing, rankings, or “best/leading” style statements, attach a support file:

• Source documents (internal calc memos, product docs, contracts, rate sheets). (FINRA Rule 2210)
• Assumptions and date ranges used to compute any stated outcomes (if present). (FINRA Rule 2210)
• Required qualifiers and limitations that make the claim not misleading. (FINRA Rule 2210)

Rule-of-thumb: if you cannot explain the basis for a claim in a short memo, the content is too risky to publish. (FINRA Rule 2210)

5) Supervise ongoing communications, not just campaigns

Set supervisory routines for:

• Post-use sampling/reviews of correspondence and other high-volume communications. (FINRA Rule 3110)
• Social media supervision: approved accounts, required training, prohibited content, and escalation when staff engage in product discussion. (FINRA Rule 2210, FINRA Rule 3110)
• Content lifecycle: periodic review of evergreen pages for staleness, broken disclosures, and product changes. (FINRA Rule 2210, FINRA Rule 3110)

6) Train the business on what triggers review and what is prohibited

Training should be role-based:

• Marketing: disclosures, fairness/balance, substantiation file expectations. (FINRA Rule 2210)
• Reps: what counts as business communication, what needs pre-approval, and what must be escalated. (FINRA Rule 2210, FINRA Rule 3110)
• Executives: social media guardrails and approval routes. (FINRA Rule 2210)

7) Wire recordkeeping and auditability into the process

Your goal is “reconstruct the decision”:

• Final content version that was published/sent. (FINRA Rule 2210)
• Review comments, redlines, and disposition. (FINRA Rule 3110)
• Approval record: who approved, when, and scope (first use vs re-use). (FINRA Rule 2210)
• Supporting documentation for claims and disclosures. (FINRA Rule 2210)

Daydream can help you map these artifacts to the requirement and maintain an evidence checklist per channel so audits do not devolve into inbox archaeology.

Required evidence and artifacts to retain (exam-ready)

Use this as your minimum evidence set:

• Written Supervisory Procedures (WSPs) covering communications review, approval, escalation, and monitoring. (FINRA Rule 3110)
• Communications Channel Matrix (classification + required approval path). (FINRA Rule 2210)
• Review/approval logs (system reports or controlled spreadsheets) showing principal approval for in-scope retail communications before first use. (FINRA Rule 2210)
• Content archive of what was actually distributed (including social posts and edits where available). (FINRA Rule 2210)
• Claim substantiation files tied to each high-risk communication. (FINRA Rule 2210)
• Training records for marketing, reps, and supervisors. (FINRA Rule 3110)
• Exception records: approvals granted after changes, emergency postings, corrective actions, takedowns. (FINRA Rule 3110)

Common exam/audit questions and hangups

Expect examiners to ask:

• “Show me your WSP section that governs retail communications and principal approval.” (FINRA Rule 3110, FINRA Rule 2210)
• “How do you determine whether something is retail communication vs correspondence?” (FINRA Rule 2210)
• “Demonstrate principal approval before first use for these examples.” (FINRA Rule 2210)
• “Where is the support for this claim and why is the disclosure sufficient?” (FINRA Rule 2210)
• “How do you supervise social media and prevent off-channel business communications?” (FINRA Rule 3110, FINRA Rule 2210)
• “What happens when content changes after approval?” (FINRA Rule 3110)

Hangups that slow teams down:

• No single system of record for approvals.
• Inability to reproduce the exact version sent.
• Disclosures exist but do not qualify the headline claim in a meaningful way. (FINRA Rule 2210)

Frequent implementation mistakes (and how to avoid them)

1. Treating disclaimers as a cure-all. Disclosures do not fix an untrue or misleading statement; rewrite the claim or remove it. (FINRA Rule 2210)
2. No “owner” for evergreen web pages. Assign a business owner and a compliance reviewer for every durable page; stale content is still a communication. (FINRA Rule 2210, FINRA Rule 3110)
3. Approval by email with no retention discipline. Move approvals into a workflow tool or a controlled repository that preserves version, timestamp, and approver identity. (FINRA Rule 3110, FINRA Rule 2210)
4. Social media policies that ignore comments/DMs. Staff engagement can become business communication; define what is allowed and what requires escalation. (FINRA Rule 2210, FINRA Rule 3110)
5. Third-party marketing content not supervised. If a third party drafts or posts on your behalf, your supervision system must cover that activity and keep the same evidence. (FINRA Rule 3110)

Enforcement context and risk implications

Even without citing specific cases here, you should plan as if an examiner will test communications controls through sampling and targeted reviews because communication failures are observable and easy to evidence. A weak program drives four real risks:

• Customer harm from misleading statements or omitted qualifiers. (FINRA Rule 2210)
• Regulatory findings for lack of principal approval and ineffective supervision. (FINRA Rule 2210, FINRA Rule 3110)
• Remediation load: takedowns, retractions, customer notifications, and re-review of large content libraries. (FINRA Rule 3110)
• Reputational damage: marketing claims are public and durable.

Practical execution plan (30/60/90 days)

First 30 days (stabilize and stop uncontrolled publishing)

• Freeze or gate high-risk channels until approval workflows exist (website edits, paid social, performance claims). (FINRA Rule 2210)
• Publish an interim communications WSP addendum: what must be submitted, who can approve, and what is prohibited. (FINRA Rule 3110)
• Stand up a central intake queue and approval log; require principal sign-off before first use for retail communications in scope. (FINRA Rule 2210)
• Start claim substantiation files for any currently live high-impact pages. (FINRA Rule 2210)

Days 31–60 (standardize and make it repeatable)

• Finalize the Communications Channel Matrix and bake it into training and onboarding. (FINRA Rule 2210)
• Implement standardized review checklists and a disclosures library. (FINRA Rule 2210)
• Define post-use sampling for correspondence and supervisory review routines. (FINRA Rule 3110)
• Centralize evidence in Daydream (or your GRC system) so each communication sample has: final version, approval, and support. (FINRA Rule 3110, FINRA Rule 2210)

Days 61–90 (operational maturity and exam readiness)

• Run a mock exam: pick a sample of communications and prove end-to-end traceability from draft to approval to archive. (FINRA Rule 3110, FINRA Rule 2210)
• Add change-control rules: what edits require re-approval and how you document it. (FINRA Rule 3110)
• Expand supervision to third parties creating or distributing content on your behalf; require contractual cooperation for archiving and review. (FINRA Rule 3110)
• Establish recurring governance: content owner attestations and periodic evergreen-page reviews. (FINRA Rule 3110, FINRA Rule 2210)

Frequently Asked Questions

Do all retail communications require principal approval before use?

Retail communications have specific principal review/approval obligations under FINRA’s communications rules, and your WSPs should define which items require documented approval before first use. Build the workflow so in-scope items cannot be published without the approval record. (FINRA Rule 2210, FINRA Rule 3110)

What’s the most defensible way to handle social media posts by registered reps?

Restrict business-related posting to approved accounts and require pre-review for posts that include product claims, performance, or recommendations. Supervise engagement (comments/DMs) through monitoring and clear escalation triggers. (FINRA Rule 2210, FINRA Rule 3110)

How do we prove a statement is not misleading if it’s technically true?

Keep a “claim substantiation” package and document the qualifiers needed for a fair and balanced presentation. If a reasonable reader could be misled without the qualifier, treat it as a required element of the communication. (FINRA Rule 2210)

What evidence do examiners usually want first?

They typically start with your WSPs, your approval workflow, and a small sample that shows principal approval and substantiation for what was sent. If you can’t reproduce the exact version distributed, fix archiving immediately. (FINRA Rule 3110, FINRA Rule 2210)

Can marketing agencies draft content, or does it have to be written internally?

Agencies can draft, but your firm remains responsible for supervising and approving content used by or on behalf of the broker-dealer. Contract for review cycles, version control, and archiving support so you can evidence supervision. (FINRA Rule 3110, FINRA Rule 2210)

What should we do when product terms change and old pages become inaccurate?

Treat it as a communications change-control event: identify impacted pages, pull or correct them, and route updates through the same review/approval process. Document the takedown and replacement so you can show control over the lifecycle. (FINRA Rule 2210, FINRA Rule 3110)