What is a content approval gap? It’s the lack of a clear, documented process for stakeholder review and approval of marketing or regulatory content. Without that process, it’s far too likely that marketing content will reach publishing channels without proper vetting. This creates material risks, especially when it comes to content that is consumer-facing and must meet regulatory agency requirements, such as that which accompanies an offer of some kind.
Why effective approval processes matter
Regulators expect accurate disclosures under laws like the Truth in Lending Act, Bank Secrecy Act (BSA), FDIC signage rules, and CAN‑SPAM TCPA email regulations. Violations can result in heavy fines: for example, each separate email in violation of the CAN-SPAM Act is subject to penalties of up to $53,088, so non-compliance can be costly.1 Unfortunately, smaller local banks often lack the dedicated workflows and compliance teams to manage these processes consistently, largely because of:
Fragmented workflows and informal processes: Community banks frequently rely on manual or ad-hoc content distribution via third parties. The use of third party resources—such as design firms and ad agencies—can exacerbate the problem, as content is often shared via email threads, making the process even more error prone. Without set-in-stone procedures, content may bypass necessary stakeholders such as legal, compliance, or leadership. One of the last things a community bank’s marketing team needs is unapproved content being published.
Limited compliance specialists: Retaining and budgeting for dedicated consumer‑compliance staff is a common challenge. Many smaller banks cannot afford full-time compliance experts, leaving marketing teams to self-navigate compliance requirements using limited resources.
Evolving regulatory complexity: As we all recognize, regulatory standards change all too frequently, and regulations like the BSA (Bank Secrecy Act), Dodd‑Frank, fair‑lending rules, and digital/fraud safeguards add greater complexity to an already challenging-to-navigate regulatory landscape. Managing those challenges without the help of digital workflow tools, such as automated content routing, is both time-consuming and error‑prone. And, as mentioned earlier, errors can be costly.
Auditability and version control: Without centralized tracking and time stamping, banks struggle to trace who approved what and when. That complicates audits and compliance reviews. In addition, reusing previously approved content becomes difficult. This adds to the time and expense of developing new content and can result in outdated, unapproved versions of content getting inadvertently published.
Personal device and off‑channel risks: When review happens via email threads, messaging apps, or personal devices, content can escape content review. Financial firms have been fined for failure to archive text communications properly, creating governance gaps.
In one instance, according to the Wall Street Journal, “Moody’s and S&P each agreed to pay $20 million to settle the allegations, according to an SEC statement released Tuesday. Fitch Ratings agreed to pay an $8 million penalty, while A.M. Best Rating Services agreed to pay $1 million, according to the SEC.
The SEC said the firms failed to maintain and preserve records of off-channel electronic communications, including texting and use of platforms such as WhatsApp. ’We have seen repeatedly that failures to maintain and preserve required records can hinder the staff’s ability to ensure that firms are complying with their obligations,’ said Sanjay Wadhwa, deputy director of the SEC’s Division of Enforcement.”2
How automated content routing closes the gap
Community banks that formalize content governance reduce risk, but those that automate the process gain real efficiency and consistency. Automation ensures every piece of content—from internal memos, email marketing, and direct mail to social posts and signage—is routed to the right stakeholders in the predefined order before publication. A best‑practice automated content routing system should:
- Enforce multi-stage approvals (e.g., marketing → legal → compliance → executive)
- Track version history, timestamps, and approvals, ensuring auditability
- Centralize access, reducing reliance on email or external channels
- Integrate branding checks and time-stamp edits for record integrity
- Preserve consistency and prevent unauthorized publishing
- Utilize a customizable, predefined order of review that the user can create, including only those stakeholders relevant to the content’s approval
Formalize compliance with automation
In a highly regulated financial services environment—one which also seems to be in constant flux—community banks that lack formal or automated content approval workflows expose themselves to tremendous risks: burdensome fines, customer attrition, and reputational damage, to name just a few. Non-compliant marketing or communication isn’t just a legal risk; it’s a business risk that undercuts loyalty and trust … and can have a significant negative impact on the bottom line.
Solutions such as Bank Marketing Center’s automated content routing system offer an alternative to taking costly risks. With enforced, customizable approval workflows and auditing built in, your bank can publish content confidently. An automated routing and compliance function ensures that every external communication is on-brand and meets regulatory requirements, eliminating guesswork and reducing the exposure that comes from unapproved content. In short, automation can transform risk into reliability.
Bank Marketing Center
We’re Bank Marketing Center, the leading, subscription-based provider of automated marketing services to community banks. Our goal is to help bank marketers with topical, compelling communication with customers that builds trust, relationships, and revenue. And we do this through automating critical bank marketing functions, such as content creation, social media management, digital asset management and, of course, content routing. All of which contribute to a community bank’s ability to create and distribute content without fear of fines, brand damage, or fleeing customers.
We also want to share what we know—and learn along the way—with all our community banking friends. Whether it’s the latest on AI technology, suggestions on how to attract and retain top talent, or the importance of data protection, we’re here to make bank marketing the best that it can be.
Want to learn more about what we can do for your community bank and your marketing efforts? You can start by visiting bankmarketingcenter.com. Then, feel free to contact me directly by phone at 678-528-6688 or via email at nreynolds@bankmarketingcenter.com. As always, I welcome your thoughts.
1Federal Trade Commission. CAN-SPAM Act: A Compliance Guide for Business. August 2023.
2Wall Street Journal. Credit-Rating Providers Settle With SEC Over Off-Channel Communication Violations. September 3, 2024