What is the mechanism and/or best practice in Marketo to enable reporting for FINRA e-mail compliance?

[Anonymous]

To be clear, this is simply a report which includes the content of the e-mail and all of its the recipients stored in an unalterable format.  We're new to Marketo and can cobble together a report based on activity history but was wondering if anyone in the community has gone through this exercise and found a method that is more Compliance-friendly or if there are add-ons/integrations to e-mail auditing vendors.  

[Anonymous]

I am not sure if we have any information around FINRA compliance. As you probably know, FINRA regulations vary based on what type of organization FINRA classifies you as (ie, broker-dealer). It might be worth hiring an consultant who specializes in these matters. 

[Katie_DenHollan]

Hi Chandler,

I know you posted this question a long time ago, but did you find a solution to stay compliant with FINRA? We are regulated by the SEC, so we also need to keep a record of email history and recipients, but have not found a good solution yet.

[Anonymous]

There's some BCC functionality in Admin that was built for financial companies that want to retain copies of every email to every recipient.

[SanfordWhiteman]

Katie, there are two main areas regarding email compliance for financial companies:

1. Email content approval (allowed marketing, disclosures, disclaimers)
2. Email archiving (inalterable journaling)

Unfortunately Marketo doesn't have anything that can be said to target either of these areas directly from a regulatory standpoint.

For #2, as Kristen says, you can have support turn on auto-BCC, which might form a foundation for journaling but will also likely overwhelm your corporate mail server.  Because every message is sent individually, this is not the typical archiving model (though if emails are personalized, it is technically accurate). You will have to build a secondary system to archive these messages in a more compact, searchable format.  We're engaged on such a project at present.

A related option is setting up a mail relay with Marketo so all of your emails go out through your own server  This enables not only archiving (though with the same caveats as above) but content inspection and possibly alteration (adding footers, etc.).

For #1, the only way you could create such a gated system would be by exclusively using the API to send email -- thus creating basically an alternate front-end for your marketers.  This would be a very large technical task, and the loss of key Marketo functionality would probably make it a non-starter.

[Anonymous]

Just to let you know where we ended up:

For content approval, we continue to use an internal process (which is unfortunately highly manual) to submit content to our compliance group and subsequently FINRA.  We are looking to automate this during the next several months but have some hurdles to break down.  I will follow-up with a post of what we come up with if its relatively eloquent. 

As for the email archiving, we ended up using the auto-BCC functionality (which, BTW, must be administratively done Marketo via a support request).  We are BCC'ing the emails to a 3rd-party archiving vendor (SMARSH) since our internal infrastructure isn't up to the task.  Just a note: we were already using this vendor for our internal archiving, so we didn't perform any due-diligence or vendor evaluations, so I can't make any qualitative/quantitative assessment of this vendor vs. others, however we haven't encountered any issues and our compliance group seems to be happy with having a single vendor. 

Sorry for the late response/follow-up, but I haven't been on the boards in a while. 

[Josh_Hill13]

I'm curious if it is possible to use the Activity sync to SFDC and if that's enough in this case. It's probably not good enough for larger financial firms though.

Is it possible to use JIRA or a similar workflow tool to manage the approvals process before loading into Marketo?

If you do happen to figure out a solution, I bet this would be a great talk at the Marketo Summit or at Martech. Perhaps you could reach out to Moody's or other Marketo financial services clients via your account manager? Maybe Chiefmartec has a couple of articles or people for you.

[Anonymous]

It’s possible, however our Salesforce Sales users don’t really want to be inundated with all of the activity that the Marketing team is generating nor do they want to pay for the extra SFDC storage.  The other issue here is that the data needs to be somewhat “immutable”, which isn’t the case when its posted into the SFDC objects.   I am sure there are creative ways to snap the data, offload it and clean it to avoid these pitfalls, however we’re a small shop and the cost of “journaling” it was low enough to justify skipping the effort. 

As far as the workflow, that’s the angle that we’re looking to take.  Unfortunately we have a handful of workflow tools from which to choose, so we need to conflate our options so that we can each a consensus on how to handle it (Jira being one of them BTW).   We’re definitely up for sharing if we come up with an eloquent solution. 

Sorry for the late response but we’ve been inundated with year-end reporting so just getting back to this thread.