How are ads reviewed in your organization? I would appreciate any suggestions if different from below.

I generally try to make sure my ads are in compliance before I submit them, though. I like to have my i's dotted and my t's crossed.

Disclaimer... I'm SUPPOSE to get them before they go to publication. It's still a new procedure so sometimes that is not the case!

I'm also supposed to review ads prior to publishing, but . . . Hence the reason for the additional review in order to make sure that all were reviewed at some point.

It took a couple of exceptions being reported to the audit committee before one office began to take the review prior to publishing requirement seriously.

all of our ads are submitted to compliance prior to publication. the FDIC exam checklist is used to ensure all i's are dotted and t's crossed. once completed, the checklist and copy of ad is signed approved and transmitted back to marketing. the original review is kept with compliance department for examiners.

I/M/O, this is a good example of the distinction between compliance monitoring versus compliance audit.

If you think about it, why is complying with ad requirements any different than complying with loan requirements? For instance, if Compliance does not pre-certify each RESPA loan for compliance (and it shouldn't) why should it pre-certify each CD ad?

Providing easily understood (and updated) checklists speeds up the ad process, demonstrates the designation of responsibility for daily compliance to the Operational Manager where the task resides, and helps free up compliance personnel to actually audit, follow-up, and dispurse information to the institution.

We have a number of new marketing personnel. I have a lot of training to do at this point before I would feel comfortable with them understanding the checklist (I'm teaching them what an APR is!). But they are generating a lot of ads that need to be reviewed NOW! and this is tying up my time. But I did want to work in the direction of getting them used to using a checklist and being comfortable with it and compliance reviewing later as we do other areas. I wondered if anyone else was brave enough to do this and what your experiences have been?

Do you charge back the fully-loaded cost of this baby-sitting service to the affected business, or (more likely) allow the business + marketeers to bury this (significant) operating cost in corporate overhead?

What costs? don't you know compliance is free (or at least the compliance officer is)! Where is that tongue in cheek emoticon?

And here you have the #1 reason why business managers and marketeers don't assume responsibility for regulatory compliance within there spheres of operation! As long as cost and accountability can be pushed onto someone else, why should they let it get in the way of doing business? By allowing regulatory cost to escape hitting their bottom line, executive management encourages these folks to engage in the most bizarre products and promotions imaginable. In effect, they become regulatory resource sponges.

At my last shop Marketing used a checklist and I would do a a periodic review. It worked out very well, but part of the reason for its success was that the head of Marketing was totally on board with the process. She actually loved the fact that she could take care of all the Compliance issues without having to track me down when she had a tight deadline. Contrast it to my present shop, where the head of Marketing absolutely refuses to use a checklist, and the culture is such that he can get away with it.

I would absolutely advocate for a checklist as long as you can get Marketing on board and educated.

And here you have the #1 reason why business managers and marketeers should assume responsibility for regulatory compliance within there spheres of operation! Regulations will always be costly and sometimes an obstacle to a particular product or promotion, but regulatory activities do not have to be a bottleneck. When business managers assume control of regulatory activities, they free themselves from the restraints inherent in the shared-compliance-officer model. If they're paying the freight, they can direct their regulatory grunts to drop everything and work on a new project any time they want!

Our process is marketing reviews all customer facing marketing material prior to sendig to compliance for their review and approval. Am certain there are things used that are not marketing and/or compliance approved.