Communications content standards

The communications content standards requirement means your broker-dealer must ensure every retail and institutional communication is fair, balanced, and not misleading, with required disclosures and a defensible basis for claims. Operationalize it by defining in-scope communications, setting content rules, routing required items to principal review, and retaining records that prove review, approval, and distribution controls.

Key takeaways:

• Build a channel-by-channel inventory and apply FINRA Rule 2210 content rules consistently ¹.
• Tie supervision and testing to written supervisory procedures (WSPs) under FINRA Rule 3110 ².
• Retain evidence of approvals, changes, and final disseminated versions under FINRA recordkeeping expectations ³.

“Communications content standards requirement” work fails for one predictable reason: firms treat it as a marketing style guide instead of a supervised, testable control set. FINRA expectations focus on whether communications to retail and institutional audiences are fair and balanced, whether risks are presented alongside benefits, whether performance and projections are handled appropriately, and whether the firm can evidence who approved what, when, and why ¹.

For a CCO or GRC lead, the fastest path to control is to translate Rule 2210 into operational decisions: (1) which communications are in scope, (2) which require principal pre-use approval, (3) what content standards your reviewers enforce, and (4) what records you keep to prove the program works. Then align the workflow to supervision and escalation under your WSPs ² and record retention practices ³.

This page gives requirement-level implementation guidance you can hand to a marketing leader, a supervising principal, and a records team and get consistent outcomes across email, websites, social media, pitch decks, and third-party content shared by registered persons.

Regulatory text

Operator-facing requirement (FINRA baseline): “Ensure retail/institutional communications meet FINRA content standards.” ¹

What the operator must do:
You must implement controls that prevent the firm from distributing communications that are misleading, omit material information, or present benefits without a balanced presentation of risks. You also need supervision and recordkeeping that proves those controls operate in practice ⁴.

How this shows up in exams: exam teams commonly trace a sample from (a) final distributed communication back to (b) approval evidence and substantiation, then forward to (c) supervision/testing outcomes and remediation. Your program passes when the sample trail is complete and consistent across channels ⁴.

Plain-English interpretation of the requirement

Your firm can market products and services, but every statement must be supportable, appropriately qualified, and presented in a way a customer can understand. If you highlight upside, you need to address downside. If you reference performance, you need the context and disclosures to avoid a misleading impression. If you compare, rank, or claim “best,” you need a defensible basis and supporting documentation. If you use a third party’s content, you still own the compliance outcome once you adopt or distribute it ¹.

Who it applies to (entity and operational context)

Applies to: FINRA member broker-dealers and their associated persons creating, approving, or distributing communications ¹.

Operationally relevant teams:

• Marketing and product marketing (web, social, email, campaigns)
• Registered reps and sales leadership (pitch decks, one-pagers, outbound messages)
• Investment/Research, if their materials are used in communications
• Compliance reviewers and supervising principals (principal approvals) ¹
• Operations/records management (books and records retention) ³
• Supervisory management responsible for WSPs, training, and surveillance ²

Channels typically in scope: websites and landing pages, email and newsletters, social posts, digital ads, seminars/webinars and invitations, brochures, pitchbooks, fact sheets, app content, and communications prepared by third parties that your firm disseminates or links to as part of a recommendation or marketing effort ¹.

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

1) Build and maintain a communications inventory (by channel and “communication type”)

Create a living inventory that answers:

• Channel: web, social, email, print, webinars, third-party platforms
• Owner: business owner and compliance reviewer
• Audience: retail vs institutional
• Communication type: retail communication, correspondence, institutional communication
• Approval required: pre-use principal review, post-use review, or other routing rules ¹

Practical tip: Put the inventory under change control. New channels (new social accounts, new domains, new ad platforms) should not go live until they appear in the inventory with an approval path.

2) Define your firm’s content standards as testable rules

Convert “fair and balanced” into checks reviewers can apply consistently. Your content standards should cover:

• No misleading statements or omissions: require material qualifiers and avoid cherry-picked facts ¹.
• Risk disclosures: risks must be clear and proximate to benefits; don’t bury key limitations.
• Performance and hypotheticals: require defined templates and compliance-approved language for performance presentation and required context ¹.
• Comparisons/claims: “best,” “safe,” “guaranteed,” “lowest cost,” “no risk,” rankings, or awards require substantiation and precise definitions ¹.
• Testimonials/third-party content adopted by the firm: require review, record of what was adopted, and any required disclosures for the way it is presented ¹.
• Brand and title usage: ensure names, credentials, and titles are not misleading.

Deliver these standards as a short “reviewer checklist” plus a longer written policy.

3) Implement pre-use/principal review routing for in-scope communications

Establish a workflow that enforces principal review for communications that require it, with:

• Submission requirements: draft, target audience, distribution list/channel, product references, substantiation attachments.
• Approver requirements: designated principals, backups, segregation of duties where feasible ¹.
• Approval evidence: approval stamp/date, approver identity, version identifier, and conditions of approval ¹.

This is the control FINRA exam teams can validate quickly because it produces clear artifacts. It is also the recommended baseline control for this requirement ¹.

Daydream fit (earned mention): Daydream is useful here as the system-of-record for the communication intake, versioning, reviewer checklists, approvals, and audit-ready evidence bundles. The value is speed during sampling, not “automation” for its own sake.

4) Write WSPs that match reality (and train to them)

Your WSPs must describe:

• Who can create and distribute content
• What requires pre-use approval vs post-use sampling
• Escalation paths for higher-risk content (new products, complex products, public-facing campaigns)
• Ongoing supervision, surveillance, and periodic testing cadence
• Consequences for bypassing process ²

Then train marketing and registered persons on the rules they can violate in one message: balanced presentation, promissory language, exaggerated claims, and missing context ⁵.

5) Surveillance and testing: prove the program works outside the workflow

Even a strong pre-use process misses “off-system” behavior (screenshots on social, edits on web pages, one-off emails). Add controls such as:

• Periodic sampling of distributed communications by channel and team
• Exception reporting (materials posted without approval, missing disclosures, stale content)
• Remediation tracking and root-cause fixes (training, template updates, permission changes) ²

6) Recordkeeping: retain what you need to reconstruct the decision

Your records program should retain:

• Final versions as disseminated
• Drafts and change history when practical
• Approval evidence and reviewer notes
• Substantiation files supporting claims
• Distribution context (where/when posted, campaign identifiers)
• Evidence of supervision/testing and remediation ⁶

Required evidence and artifacts to retain

Keep these artifacts in a form you can produce quickly:

Artifact	What it should show	Why it matters
Communications inventory	Scope, owners, approval rules by channel	Demonstrates control design 1
Written content standards	Specific checks and prohibited/conditional claims	Consistency and training anchor 1
WSP section for communications	Supervision, approvals, escalation, testing	Required supervision evidence 2
Approval records	Who approved, date/time, version, conditions	Primary exam sample trail 1
Substantiation package	Sources/calculations for claims, performance support	Defends “reasonable basis” 1
Distribution evidence	Screenshot/archived page, send logs, posting records	Confirms what customers saw 3
Surveillance/testing results	Sampling plan, findings, remediation	Proves ongoing supervision 2
Training records	Attendance, attestation, materials	Shows policy adoption 2

Common exam/audit questions and hangups

Expect questions like:

• “Show me your definition of retail communication vs correspondence vs institutional communication, and how you route each for review.” ¹
• “Provide evidence the approving principal reviewed this exact version before first use.” ¹
• “What is your substantiation for this claim, comparison, ranking, or performance statement?” ¹
• “How do you supervise social media and web content that can change after approval?” ²
• “Where are your books and records for these communications and approvals?” ³
• “How do you ensure third-party content you share is compliant once adopted?” ¹

Hangup to plan for: “We approved the deck, but sales used a modified version.” Your controls need to prevent or detect field edits.

Frequent implementation mistakes and how to avoid them

1. A policy with no routing control. Fix: make the approval workflow mandatory for publication/email sends, with restricted permissions.
2. No substantiation discipline. Fix: require substantiation attachments for objective claims before review completion ¹.
3. Treating websites as static brochures. Fix: require archived snapshots and post-change approvals for material edits ³.
4. Over-reliance on “approved templates” without monitoring drift. Fix: periodic sampling of actual distributed items and template lock controls ².
5. Uncontrolled third-party content sharing. Fix: define “adoption” rules and require review before reps share third-party pieces ¹.

Enforcement context and risk implications

No specific public enforcement cases were provided in the source catalog for this page, so this guidance focuses on baseline rule expectations and what exam teams can validate through artifacts and supervisory testing ⁴.

Risk outcomes to plan for:

• Regulatory findings for misleading communications or missing approvals ¹.
• Supervisory control findings where WSPs exist but the firm cannot prove they operate ².
• Books and records issues where the firm cannot produce what was disseminated and who approved it ³.

Practical 30/60/90-day execution plan

Day 0–30: Get control of scope and approval

• Appoint a single business owner for communications supervision with Compliance and Marketing counterparts ².
• Build the communications inventory and classify communication types by channel ¹.
• Stand up a minimum viable pre-use/principal approval workflow for the highest-risk channels (public website pages, mass emails, public social accounts) ¹.
• Publish a short content standards checklist for reviewers and creators ¹.
• Decide where the official record lives (repository/tool) and how you capture final disseminated versions ³.

Day 31–60: Harden WSPs, templates, and evidence

• Update WSPs to match the real workflow, including escalation and exceptions ².
• Build substantiation templates (claims log, performance support pack, comparison support pack) ¹.
• Add controls for versioning: unique IDs, locked PDFs, and controlled distribution lists.
• Train marketing and sales on top failure modes and require attestations ².
• Pilot surveillance sampling on one channel (social or email) and track remediation in a ticketing system ².

Day 61–90: Prove ongoing supervision and close gaps

• Expand surveillance/testing across channels, including off-system behavior ².
• Run a mock exam sampling: pick distributed items and reconstruct the full evidence trail ⁷.
• Fix structural issues: permissioning, bypass routes, unclear ownership, missing archives.
• Operationalize metrics that matter operationally (exceptions, aging approvals, repeat findings) without turning them into vanity reporting.
• If you adopt Daydream, configure standardized evidence bundles so each sampled item exports with approvals, substantiation, and final version in one package.

Frequently Asked Questions

What counts as an “in-scope communication” for communications content standards?

Treat anything that could influence a customer’s decision or perception as in scope, including web pages, emails, social posts, pitch decks, and seminar materials ¹. Classify by communication type and apply the right review path.

Do institutional communications need the same level of review as retail communications?

The content still must meet FINRA standards against misleading statements ¹. Your workflow can be different by classification, but you need documented rules and supervisory oversight in WSPs ².

How do we handle “last-minute” marketing changes without blocking the business?

Use pre-approved components (risk disclosures, standard product descriptions) and require a rapid principal review lane for edits that change meaning, claims, or comparisons ¹. If it can’t be reviewed, it shouldn’t be distributed.

Can registered reps share third-party articles or charts without review?

If the firm or rep adopts or distributes third-party content as part of a recommendation or marketing message, you still own the compliance outcome ¹. Set clear rules for what is prohibited, what needs review, and what can be shared only with specific context.

What evidence is most persuasive to FINRA examiners?

A clean sample trail: final disseminated version, principal approval record tied to that version, and substantiation for objective claims ¹. Back it with WSPs and surveillance/testing results ² and record retention controls ³.

We already have an archiving tool. What gap does Daydream address?

Archiving shows what was sent or posted; it often does not show the full pre-use decision trail and substantiation in one place. Daydream can centralize intake, versioning, principal approvals, and evidence packaging so you can answer exam sampling requests quickly and consistently ⁷.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. FINRA Rule 2210

2. FINRA Rule 3110

3. FINRA Rule 4511

4. FINRA Rule 2210; Source: FINRA Rule 3110; Source: FINRA Rule 4511

5. FINRA Rule 2210; Source: FINRA Rule 3110

6. FINRA Rule 4511; Source: FINRA Rule 3110

7. FINRA Rule 2210; Source: FINRA Rule 4511