Campaign Performance Checklist

Workflow a financial-services marketing team runs to plan, launch, and close out a client-facing campaign in compliance with FINRA Rule 2210, the SEC marketing rule, and firm books-and-records requirements.

1

Campaign Setup and Compliance Intake

  1. Define the campaign objective and KPI targets
    • State the business objective (lead generation, AUM growth, plan rollover capture, deposit acquisition) and the measurable KPI targets — qualified discovery meetings booked, funded accounts, cost per qualified lead. Vague objectives like 'awareness' make principal review and post-campaign attribution impossible.

  2. Classify the communication under FINRA Rule 2210
    • Determine whether the piece is retail communication, correspondence, or institutional. Retail communication distributed to more than 25 retail investors in 30 days requires principal pre-approval and triggers FINRA filing if it falls in a covered category (e.g., registered investment company materials).

  3. Add the campaign to the CCO advertising calendar
    • Log the campaign in ComplySci, RIA in a Box, MyComplianceOffice, or your firm's equivalent so the CCO has visibility into in-flight advertising and can map it to the annual Rule 206(4)-7 review.

2

Audience Targeting and Segmentation

  1. Define investor segments and AUM tiers
    • Specify investable-asset thresholds, life stage (accumulator, pre-retiree, retiree), and planning complexity (equity comp, business owner, inheritor). The segmentation directly shapes whether a recommendation later triggers Reg BI obligations or qualifies as institutional.

  2. Segment the CRM list by lifecycle stage
    • Pull segments from Wealthbox, Redtail, or Salesforce Financial Services Cloud — separating prospects, dormant leads, current clients, and centers of influence. Mixing client and prospect lists in a single send creates message-targeting mismatches and Reg S-P privacy issues.

  3. Apply do-not-contact and opt-out suppression
    • Suppress unsubscribes, complaint-log contacts, restricted-list names, and any prospect who exercised a Reg S-P opt-out. CAN-SPAM and TCPA still apply on top of securities rules; one improperly contacted unsubscribe can become a complaint that lands in the next audit file.

3

Creative, Disclosures, and Principal Review

  1. Draft the headline and value proposition
    • Write claims that are substantiable. The SEC marketing rule (206(4)-1) prohibits untrue or unsubstantiated statements of material fact. 'Top-rated' or 'award-winning' language requires the underlying methodology and timeframe in the same piece.

  2. Add required disclosures and disclaimers
    • Include the firm's registration disclosure, performance presentation conditions if any returns are shown (gross/net, time-weighted, benchmark, time period), past-performance qualifier, and links to Form ADV Part 2A and Form CRS. Testimonials and endorsements need the disclosures required under the amended marketing rule.

  3. Submit the creative for principal pre-approval
    • Upload the final creative — copy, images, landing page, and any video — to the compliance review queue. Retail communication under FINRA Rule 2210 requires written principal approval before first use; ComplySci, Smarsh, or Hearsay capture the audit trail.

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  4. Capture the principal review decision
    • Record the principal's decision verbatim along with their reviewer ID and timestamp. A 'rejected' or 'revisions required' result must block launch — campaigns that go live without sign-off are the most common Rule 2210 finding in branch audits.

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  5. Revise the creative and resubmit for approval
    • Address each reviewer comment, document the change rationale alongside the original markup, and route back through the same approval queue. Do not launch from a partial verbal approval — the books-and-records file needs the second written sign-off.

4

Budget, Bidding, and Channel Allocation

  1. Set the budget cap and target CPA
    • Anchor the target cost-per-acquisition to the lifetime advisory fee economics of the segment, not to industry benchmarks. A $400 CPA is reasonable for a $1M+ prospect pipeline; the same CPA is upside-down on a one-time financial-plan engagement.

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  2. Choose the bidding strategy per channel
    • Match bid strategy to objective: max-conversions for lead-gen with proven creative, target-CPA once the pixel has 30+ events, manual CPC for new creative still in learning. Don't enable smart bidding until the conversion event is firing reliably.

  3. Allocate spend across approved channels
    • Confirm each platform is on the firm's approved channel list and that any rep social posts route through Hearsay or Smarsh Connected Capture. Off-platform LinkedIn posts by individual advisors that promote the firm are still firm communications and need archiving.

5

Performance Tracking and Mid-Flight Review

  1. Configure conversion tracking and UTM tags
    • Map the conversion event (calendar booked, form submit, asset-aggregator linked) into the CRM with consistent UTM parameters. Without UTMs the CRM can't attribute funded accounts back to the campaign 60–120 days later when the prospect actually onboards.

  2. Stand up the stakeholder KPI dashboard
    • Build a single dashboard the CMO, CCO, and lead advisor all read from — impressions, qualified-lead volume, CPA, and any complaint-log entries tied to the campaign. Conflicting numbers from separate spreadsheets erode trust in the program faster than weak performance does.

  3. Run the mid-flight performance review
    • At the midpoint, compare actual CPA and qualified-lead volume against the targets set at kickoff. Classify the campaign so the team knows whether to keep spending, optimize, or pull the plug — and so the post-mortem has a defensible decision point on record.

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  4. Pause or pivot the underperforming campaign
    • Decide whether to pause spend, swap to the runner-up creative, or shift budget to a better-performing segment. Any new creative or material change to copy goes back through principal pre-approval — pivots don't bypass Rule 2210.

6

Close-Out and Books-and-Records Retention

  1. Generate the final performance report
    • Reconcile platform spend against the GL, attribute funded-account dollars where conversion data is available, and capture lessons learned. Performance claims that show up in future pitch decks must trace back to this report's underlying numbers.

  2. Archive creative, approvals, and audit trail
    • Retain final creative, principal approval records, distribution lists, and stakeholder reports under Advisers Act Rule 204-2 (RIAs) or Exchange Act Rule 17a-4 (BDs) — five years minimum, first two readily accessible. Off-channel emails about the campaign also need to land in Smarsh or Global Relay.

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  3. File the post-campaign report with the CCO
    • Hand the closed file to the CCO so it folds into the annual Rule 206(4)-7 compliance review and the next branch or mock audit. Include any complaint-log entries and the disposition of every revision required during principal review.