Why Educational Ads Aren't Archived Like Your Personal Social Media

Many firms are accustomed to using tools like SMARSH to archive posts, ads, and comments on their company's social accounts. Occasionally we'll have advisor offices ask if that's possible on their Steep campaigns. The goal of this article is to help you and your compliance team understand the difference between your firm's content and the ads we run from our educational brands and how that impacts your compliance.

The ads we run for you come from an educational/media brand that Steep owns and operates, not from your personal or firm-branded social media account. Because they're unbranded ("blind") and delivered as targeted paid placements rather than organic posts to a public page, they fall outside the scope of the "capture your own social media" requirement that applies to content you personally publish. That does not mean compliance doesn't apply — it means a different part of your firm's policy applies, and you're still responsible for making sure it's followed.

Most firms' e-communications policies are built around a simple assumption: content posted to your own social media page, under your own name or your firm's name, needs to be captured and retained because it's your business communication. That's the right rule for organic, branded content — and it's why tools like Smarsh exist to archive an advisor's personal and firm pages.

•Not your channel: the ads run from Steep's brand accounts, not your firm's or your personal social media account, so they aren't “your social media” for archiving purposes.

•Not organic: they're paid, targeted placements shown only to a defined audience rather than posts published to a public feed. Social archiving tools are generally built to capture organic page activity, not targeted ad delivery.

•Shared infrastructure: a single ad account or page runs campaigns for many advisors at once, so it can't be wired into one individual advisor's personal archive tool, and campaign-level insight can't be isolated to a single advisor the way a personal page can.

•Unbranded and topic-focused: the ads don't name you or your firm, don't solicit specific products or services, and don't market on behalf of any one firm — they're educational, top-of-funnel content.

The ads are only the first step. When someone clicks through, they land on a Steep landing page that's co-branded with the advisor. Any landing page, website, or follow-up content that is branded to you or your firm should be captured under your firm's own e-communications policy, the same as any other advisor-branded content, and reviewed/approved by your compliance team.

• We produce the ad creative as unbranded ("blind") content — it is not published to your personal or firm social media page.

• We can provide copies of ad creative to your firm's compliance department on request, so they can review it independently of your organic social review process. These can also be archived in your traditional archive system.

• Our ads are built to stay topic-focused and educational — they do not solicit specific products or services or market on behalf of a specific firm.

Compliance requirements vary by firm, broker-dealer, and RIA, and this article isn't a substitute for your own firm's policy. Before and while running any third-party marketing program, you (or your firm's compliance team) should:

• Confirm your own firm's policies and procedures for reviewing and approving advertising before participating in any third-party marketing program.

• Follow your firm's own e-communications capture policies for anything published under your name or your firm's brand — including any landing page or website the ads drive traffic to.

• Make sure your compliance department has reviewed and approved the destination page(s), not just the ad creative.

• Reach out to us any time you want a copy of ad creative to hand to your compliance team, or if your compliance team has questions about how the campaigns are run.

Blind, unbranded educational ads and your personal branded social media are two different types of content with two different compliance touchpoints. We handle the part that's ours — producing unbranded creative and making it available for your compliance team's review. You and your firm are responsible for your own policies, your own e-communications capture, and for reviewing and approving anything published under your name, including the pages our ads point to.

This article summarizes general industry practice based on conversations with compliance professionals and is provided for informational purposes only. It is not legal or compliance advice. Requirements vary by firm, broker-dealer, and RIA — always confirm specifics with your own firm's compliance department.