Marilyn Dale |
To leverage press in these ways, articles that mention your mutual fund by name or that you plan to link to on your fund website must be treated as advertising for compliance purposes. Below, we’ve outlined the general steps you need to take to ensure all your i’s are dotted and t’s are crossed when republishing press mentions. Be sure to check with your own compliance experts for their guidance and approval. And the rules for leveraging reprints in social media are changing. We will have more on that in a later article.
Here’s a good checklist to get you started:
1. Seek reprint permission and pricing from the publication – sometimes necessary even for a web link.
2. Prepare the article for compliance review, attaching all relevant disclosures and performance, if needed. Articles that mention holdings typically require disclosing the percent of that holding in your portfolio. Where performance, rankings or ratings are mentioned, there will be the need for standard performance for your fund and the comparison group(s). The FINRA rules spell out the requirements, and interpretations by compliance professionals change from time to time.
3. Submit the article with disclosures to your compliance review entity. In our experience, most are willing to help you find a way to use the article; however while some publications are willing to allow you to use just excerpts or to remove a sentence or two, many are not. In those cases, posting just the title and publication can still help your fund build credibility.
4. Respond to any changes requested by compliance with new/updated information.
5. Purchase the article from the publication by completing their contract or order form.
6. For print, finalize the order indicating quantity, color vs. black/white, shipping and billing information. Disclaimer, highlighting, company logo and contact information can typically be added for an additional charge.
7. For web posting: receive a PDF of reprint or a designated URL for the reprint from the publication and submit it to your Webmaster to be posted with instructions that include:
a. All disclosures as approved by compliance and whether they need to be on a jump page or at the bottom of a specific page or two where the listing will be.
b. A link (url) to article or PDF of reprint. In the event the article in its entirety is not approved by your compliance professionals, consider a “dead” link, which is showing the http://www address for the article, but not actually providing a link. Many compliance professionals will allow this.
c. Properly sized screenshot in jpg format
d. Directions for which page(s) to post the media listing (i.e. Home page, News page)
e. Specifically what the listing should say, such as:
-Home Page: John Doe featured in MoneySmarts – May 19, 2011
-News Page: John Doe featured in MoneySmarts discussing his views for ongoing economic recovery - May 19, 2011
f. Indicate if any existing “older” listings on home page should be removed from home page but remain now only on News page
g. Review the web page and resubmit it to Compliance for final approval before going live
This process is not “hard,” but it can be very time consuming and at times frustrating, since FINRA comment letters your compliance professionals receive regarding other fund company submissions may influence, and seemingly change, their opinion on a current submission. But no pain, no gain. There is no price to be put on a great story in a credible publication and repurposing these pieces greatly multiplies their worth. If you earn the press coverage you deserve, but don't have the time to leverage it in your other sales and marketing efforts, let us know. Maybe we can help by managing your reprints. Email me for more information.
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