Compliance is an important topic for any industry, but it is particularly essential for financial services providers. Compliance regulations help to maintain the integrity of the financial institution and provide stability for the market as a whole. We sat down with Thomas Royer, Senior Manager of Compliance at Rakuten Marketing, and Joan Alpogianis, Director of Client Services, to understand more about the role of compliance for financial services advertisers, as well as how our teams provide compliance oversight for them.
Q: How integrated is compliance into the day-to-day functions of managing a program for a financial services client?
Joan Alpogianis (JA): Without compliance there simply wouldn’t be a financial program. From the onboarding process, publishers understand the rules to participate in an issuer’s program and the consequences when rules are broken. A strong compliance foundation provides our client services teams with the peace of mind to focus on driving strategy and performance.
Thomas Royer (TR): Issuers, specifically within the financial vertical, operate with certain inherent risks. This could be financial, legal, operational, or reputational risk. When they trust an affiliate network with helping to reduce and mitigate these risks, they expect exemplary results. Along with performance metrics to drive the bottom dollar, compliance is essential to ensuring these risks are mitigated to eliminate the potential loss in revenue (i.e. fines, legal implications, reputational damage, etc.).
Q: What is unique about Rakuten Marketing’s compliance offering?
TR: We employ a unique blend of automation with a hands-on approach. We have a diverse team with experience on the financial institution side as well as in the affiliate space. Our experience and processes allow us to build a program specific to the needs of the issuer. As a result of our process, we actually have a failure rate of less than 1%, compared to the 8% average failure rate financial institutions see on their own.
JA: Like Thomas said, our process is a combination of both automated tools and hands-on manual auditing. We feel both are required, one supporting the other. Best practices are also shared across the network. For example, we have a very rigorous onboarding and product update process for financial publishers which can include compliance training and product mock-ups pre-launch.
Q: Can you tell us a little bit more about this bespoke compliance process?
TR: Our team is completely hands-on through the onboarding of an issuer to the live content with publishers. We require mock-ups from publishers before they go live to ensure the material is accurate before launch. After a publisher goes live, we review it again and then on a weekly basis. We continue this process throughout the relationship with any issuer.
JA: The client services team maintains a master publisher list with all the compliance contact information on every publisher joined to a financial services issuer. This is critical, especially during product updates when we need to get hold of a partner after hours for immediate action on an item.
TR: Over time, we have seen that after a client decides to come on board, they are pleasantly surprised at the level of detail we employ with audits, reviews, publisher onboarding, and overall the professional level of compliance we provide.
Q: We know not everyone is perfect so what happens if you find a violation?
TR: If it’s found to be a customer impacting violation, we remediate immediately, taking whatever steps necessary to ensure the content is corrected. If the violation is not customer impacting, we work with the publishers to update the content and provide feedback along the way.
JA: Along the same lines, if the issue is customer impacting, the client services team will partner with the compliance team to help assess the impact, understand the root cause and determine remediation steps to resolution.
Q: Tell us about how you work with publishers.
TR: We are extremely transparent with publishers from the very beginning of the relationship. We communicate our expectations as well as those of the issuer. We provide a compliance training to ensure they understand the Terms & Conditions as well as expectations. We hold them to these and provide feedback often.
Q: Anything else you think brands or publishers need to know?
TR: We understand their business. We have the experience and the technology to create programs specific to their needs. Our system of best practices has a proven track record to keep our in-market error rate under 1%.
If you are interested in learning more about Rakuten Marketing’s compliance program, reach out to your account team or Advertiser Support here.