Category Archives: Compliance

600 Advisors: Scaling a Broker-Dealer’s Social Media

Money Concepts is an independent broker-dealers based in Florida. When they made a commitment to increase their support of social media for their more than 600 advisors around the country, they were concerned about the workload this could create for their compliance department.

That’s when they turned to Gainfully to support their program. In this case study we’ll take a look at how they have been able to offer success-oriented social media across Facebook, LinkedIn, and Twitter while keeping compliance overhead extremely low.

Program Goals

The Money Concepts leadership and Gainfully success team worked to design a program that could achieve a number of specific goals. First, Money Concepts wanted to ensure that all of their advisors could access the program. This includes scaling the program so that advisors aren’t left behind for cost or logistics reasons. It also requires that any advisors regardless of technical proficiency can access the program, not just younger power users.

Secondly, a goal of equipping advisors with not just the technology and compliance, but also the marketing content to share was very important: Money Concepts knew from experience that without content it’s impossible for small or solo offices to effectively utilize any program they might deploy.

Thirdly — and related to the first goal of offering the program to all advisors — the resulting workload for compliance needed to be manageable and fit into the existing workflow for their compliance group. Only Gainfully could offer this experience.

Results: Staggering Scalability

The Gainfully content algorithm works to always prioritize content that is A. already approved (or whitelisted) B. performing well with clients, and C. reinforcing value for the firm. This means that when you approve a content item, it’s automatically prioritized for any additional advisors within the firm.

The effect of these recommendations are to recycle the effort of your compliance team on any reviewed item, ensuring that the time and cost spent reviewing is leveraged many times over. The results of this are easy to see in the graph below, which shows how, even as advisors and content sharing activity increases linearly, the compliance costs

Blue “shares” show the number of content items shared by advisors on the platform. Grey “advisors” are the total number of advisors in the program. Red “All reviews” are the total number of compliance ad reviews needed to support the entire program.

Recommendations also come into effect in sharing behavior: when a Money Concepts advisors build their personal libraries for automatic sharing, cards will first be prioritized to be shared immediately. Then, only as the queue ranking of unapproved cards rises will the card be “triggered” for review.

Added together over the life of the program, and comparing it to the time required for any three models that Gainfully’s content engine replaces, Money Concepts has saved in excess of 4 months of man-hour time over the past 6 months.

Breaking Down how Gainfully Helped

10,000 Shareable Content Items in 5 Minutes

The first step in configuring Gainfully for Money Concepts was to add a long list of their preferred providers and conditions for whitelisting these providers. Because Gainfully builds a master library as a service that draws on the content published by over 300 leading financial services companies, broker-dealers like Money Concepts can choose to leverage their expertise and experience in creating client-facing content to providing instant and ongoing access to a massive set of content resources.

In this particular case, Money Concepts chose to whitelist content from 46 different FINRA-regulated firms if it was marked as non-advertising content, included a FINRA clean letter, or was broker-dealer use only. This set of filters enabled their over 600 advisors to discovery about 10,000 shareable content items without any additional prior-review.

Customized App Features to Accelerate Use

To streamline the publishing experience, Money Concepts chose to disallow the advisor-provided comments field, removing a step that can cause friction both for advisors and the compliance teams.

The comments field is often treated as an open space for editorializing on content. By disallowing this field Money Concepts compliance could remove the “what to say” question while also reducing their compliance review by about 50%.


Without an editorializing capability, the content is shared with one of a preset comments on the content and greater sharing activity and compliance adherence is the result.

Original Content & Content Discovery

In addition to the instant library of ~10,000 items, Money Concepts’ marketing team leveraged their in-house content strategy to augment their advisors’ experience and provided an additional layer of service.


Their content includes shareable video profiles for dozens of their advisors, enabling the advisors to quickly share a personal video to any of their social media accounts and let prospective clients “face to face”.

If an advisor sought out additional content, they can also request that it be approved and made available, either by a direct “request” or by just adding it to their personal library.

3 Social Models Broker Dealers Need to Avoid

Enabling financial professionals  — advisors, brokers, agents, wealth managers — to not just use but succeed with social media marketing poses a number of challenges. Regulatory compliance, combined with the need to generate an order of magnitude more client-facing content is a perfect storm for firms juggling many issues like DOL compliance, or simply avoiding the hazards with existing technology like email.

Combine this environment of regulatory compliance with financial professions who are not always natural marketers, not always excited about learning new and complicated technology, and many of whom have unique and often independent business models and you have a recipe for a high-cost, low reward program.

And yet, consumers and investors are using the social web ever more to evaluate service providers and learn about financial ideas and products. Moreover, many financial professionals have seen great success by embracing social media. So, as Paul Tyler, the Chair of the LIMRA-LOMA Social and Digital Business Committee provocatively asked, “how do we get greater agent adoption of the social marketing tools we already offer?”.

First Generation Approaches

Over the past 5 years a few approaches have been developed to deploy social media programs for financial professionals. The lack of time for marketing and regulatory compliance requirements have driven content solutions in financial services in three different directions, each of which have significant problems:

  1. One-to-One Pre-Approval
  2. Pre-Approved Third Party Library
  3. Supervised Open-Posting

We’ll deal with each of these three models, the relative benefits of each, and the inevitable drawbacks that make each unworkable options in ultimately ensuring social media can be successful for financial professionals.

One-to-One Pre-approval

In this model, financial professionals submit social content (and content in general) to be reviewed and approved for their individual use. This approach ensures a high degree of compliance confidence. However, while well-suited for proprietary content, such as private research, presentations, etc., this approach will fail very quickly within social media program as it scales.

The simple reason is that, as advisors submit content to be approved, the workload on ad review teams rises in direct proportion to the number of advisors.


Combine this with the fact that most advisors to not combine content approval with a content re-sharing mechanism (that will share the content multiple times) and the outcome will be high direct (costs paid by the financial professionals to support such a program) and opportunity costs (when the friction and direct cost of the program ensures the program cannot be successful for the financial professionals).


Moreover, further opportunities are missed when approved cannot be (or is not) leveraged by other eligible users in the firm, something the third party library model, which we’ll address next, attempts to solve.

Pre-Approved Third Party Library

Libraries of pre-approved content offer an initially promising way to ensure a high level of compliance while offering a larger selection of content for financial professionals to use. The benefits of exposing a library to many of your eligible financial professionals means that  many can take advantage of the library, typically numbering between 50-500 items.

In addition, compliance teams have a “place” they can sent their financial professionals to, ensuring they can discover content that is immediately shareable. However, with a growth of users this model inevitably runs into an issue: these libraries are static, and often not easily populated with additional content. This means that the value of the content rapidly diminishes as time elapses and as advisors enter the program.


Here’s an example originally collected by Matthew Zeitlin over at Buzzfeed. “One thing the new policy promises, less of this: where Morgan Stanley advisers across the country were all saying the same thing”:

From this example, it’s clear that a commitment to diversity should also extend to the language and messaging they extend to their clients on social media. The point is not that there is a risk of mockery (though there is), its that advisors look impersonal.

Supervised Open-Posting

With FINRA’s increasing tolerance for dynamic content, many firms have chosen to forgo the costs involved in pre-reviewing some or all content. This provides a huge amount of freedom to financial professionals. But the challenge is answering the “now what?” question: once they are free to do anything, their supporting firms can provide information and even coaching about what to do next, but the professional doesn’t have a service-oriented structure in which to continue developing.


The inevitable conclusion for most is, absent a guiding service, social media will cease to be a priority in the context of their other obligations. Both they and the firm lose: the professional loses unknown business and their firm loses an opportunity to empower their advisors when they could be building their business and both of their revenues.

The bottom line: users need content to succeed. It’s not the entire solution, but content and a content strategy is what ultimately shapes their brand and reflects yours.

Introducing Card Review

Today we’re releasing Card Review, a new addition of Gainfully’s content policy capabilities that will put more power in the hands of compliance professionals. The Gainfully Card Review process provides an end-to-end solution so agents and advisors can coordinate directly with compliance to identify and approve social-enabled content from across the financial services industry.

With over 30,000 content cards from over 400 industry-leading firms, Gainfully Review is designed to help regulated firms more nimbly address the challenges and opportunities of content marketing and social sales.

Any regulated firm can utilize Gainfully’s content policy framework and we’re pleased to offer its capabilities at no cost to qualifying broker dealer and RIA firms for a limited time. Contact our team at [email protected] for details on getting started.

How Review Works

Review whitelists your favorite strategic partners, connects you to their best ideas, and brings it all into a single view so your marketing and compliance teams can, if needed, review them with remarkable efficiency. Need to have a FINRA letter for some of the content? No problem. Want a fully auditable approval process with unlimited audit trail capability? Done.

Our approach is different because we remove unnecessary complication. You proactively identify your content providers, the terms and process of your review, your overall content and review policy…Gainfully handles the rest.

Why We Built Review

Financial professionals must be in constant conversation with their networks and clients to be and stay relevant. To do so you need compliant and high quality content. Our system is designed to find the best content for financial professionals to share and to do so within a framework that is proactively supported by compliance. It’s easy, efficient, and better than trying to create content that requires an individualized review process.

Review leverages content created by firms who work with advisors and agents already, bringing it into a discoverable and reviewable content network. An adviser or agent can quickly select from 1,000’s of ideas that are ready for public consumption, shareable and brandable with just a click.