The Real Risk of Informal Review (And Why It’s Still Everywhere)
Most RIAs are still handling advertising and marketing review the same way they did before the SEC’s Marketing Rule changed everything, informally. Recent SEC enforcement actions have shown that informal review processes — even for small firms — can lead to five-figure penalties. Approvals are exchanged over email. PDFs are marked up with comments and passed around. Sometimes, approvals are verbal or implied. These legacy methods don’t just risk process confusion. They risk fines.
And yet, they persist. Why? Because they’re simple. Because they’ve “worked so far.” Because scaling a firm’s marketing capacity has outpaced scaling its review process. Most RIAs are investing in more content, more campaigns, and faster execution. But compliance infrastructure hasn’t kept up.
The result is a growing fragility beneath the surface: materials going out unapproved, version confusion, missing documentation, and content edits that don’t get re-reviewed. All of this makes the firm vulnerable, not just operationally, but legally. And when the SEC starts asking questions, this patchwork process is the first thing that gets exposed.
SEC Rule 206(4)-1: What the Regs Really Demand in Practice
The SEC’s Marketing Rule (Rule 206(4)-1) isn’t new anymore, but firms are still being caught flat-footed by its practical enforcement. The rule mandates that advisers not only review all marketing materials prior to use, but also maintain records of the review process.
This includes:
- What content was reviewed
- When it was reviewed
- Who approved it
- Under what policy or rationale the approval was made
These expectations sound reasonable, but most firms underestimate what they truly imply. “Review” doesn’t just mean someone glanced at the content. It means there is a traceable, defensible workflow behind the approval. “Records” doesn’t just mean storing the final PDF. It means maintaining a log of all review actions: who did what, when, and why.
What’s catching firms off guard isn’t the content of the rule, it’s the level of process maturity the SEC is now expecting as the standard. And it’s exposing just how ill-suited CRMs are to deliver that on their own.
Why CRMs Are the Right Front-End, But the Wrong Control Layer
To be clear: your CRM is where this process should start. It’s where your team manages campaigns, client data, and communication pipelines. It’s where content is distributed and tracked. That makes it a logical point of submission for advertising review.
But CRMs weren’t designed for compliance control. CRMs excel at relationship management, not regulatory defensibility.
They don’t:
- Enforce role-based review workflows
- Lock and archive approvals immutably
- Capture policy rationales tied to each decision
- Provide time-stamped logs that examiners can audit
- Prevent post-approval edits from slipping through
A CRM may allow an advisor to upload a file or add a note, but it cannot produce an SEC-grade audit trail. And when something breaks, when a reviewer misses a risky claim or a version gets sent prematurely, the CRM provides no defense.
That’s not its fault. It just wasn’t built for this. Which is why compliance infrastructure needs to be layered underneath, not bolted on top.
The 5 Critical Stages of a Fully Compliant Ad Review Workflow
A marketing review workflow that truly satisfies the SEC’s expectations, and shields your firm from downstream risk, follows a very specific structure. Here are the five stages you need:
1. Submission
Materials must be formally submitted for review, not just shared informally. Metadata (e.g., channel, audience, campaign) should travel with the content.
2. Routing
Reviews should be assigned based on content type, risk profile, or organizational rules. A social post may route to one reviewer. A performance ad may require two.
3. Review + Edit Tracking
All feedback, suggestions, and changes must be logged and version-controlled. Reviewers need to work in a system that captures every edit and comment.
4. Approval
Approvals must be linked to reviewer identity, time-stamped, and include a reference to the rule or policy supporting the decision.
5. Archiving + Audit Reporting
Final assets and all review activity must be stored in a searchable system, one that can generate examiner-ready reports in minutes, not hours.
Miss any one of these steps, and your process isn’t just inefficient, it’s incomplete.
How CRM Integration Works Without Breaking Workflows
The good news? You don’t have to abandon your CRM. In fact, the right integration allows you to preserve advisor workflows while enforcing compliance standards in the background.
Here’s how it works with a platform like Smartria:
- Advisors initiate review requests directly within the CRM
- Campaign metadata is automatically synced (e.g., who submitted it, what product it supports)
- Compliance receives a routed task, tied to policy-based rules
- Review and approval happens within a structured, centralized compliance interface
- Final decisions are locked and archived in Smartria, not lost in a spreadsheet
This model gives compliance teams the infrastructure they need without forcing advisors to change how they work. It aligns both functions on the same timeline, with far less friction.
What Examiners Are Really Looking For (and What to Show Them)
When the SEC examines your firm, they aren’t just flipping through a folder of advertisements. They’re asking to see how those ads were reviewed, and whether you can prove it.
Here’s what they typically ask for:
- A list of all marketing materials created or used during a period
- Approval logs showing who reviewed each piece and when
- Evidence of policy adherence or rationale for high-risk content
- Archives of older drafts and version histories
- Documentation of any edits made post-approval
If you’re relying on email threads, shared folders, or manual tracking, assembling this is a scramble. But with integrated ad review systems, these records are already in place, and exportable in just a few clicks.
That difference could mean avoiding a deficiency letter, or worse.
Case Study: What Happened When a $400M RIA Integrated Review
Within 90 days of integrating Smartria into its CRM, a $400M RIA cut review times by 40% and passed its next exam with zero deficiencies. Campaign assets were emailed to compliance, reviewed in Word docs, and then stored in shared drives. The team worked hard, but the system worked against them.
After implementing a CRM-integrated Smartria workflow:
- Review cycle times dropped by 40%
- Examiner-ready documentation could be produced in under five minutes
- Internal confusion over “which version is approved” was eliminated
- Marketing and compliance began working in sync, not conflict
They didn’t just pass their next exam. They redefined what collaboration looked like.
What to Do Now: From Patchwork to Platform
The SEC’s expectations aren’t softening. If anything, they’re accelerating. And the firms being penalized today are often the ones who thought they were compliant, until examiners asked for evidence.
You don’t need to reinvent your CRM. You don’t need to retrain your advisors. But you do need to upgrade the underlying system that protects your approvals, archives your logic, and proves your process.
That’s what compliance infrastructure is. And that’s what Smartria delivers.
See how Smartria transforms your CRM into a compliant marketing engine.
