It’s Complicated. It’s Way Too Complicated.
The 2009 romantic comedy, It’s Complicated, is a humorous look at relationships. The relationship between Registered Investment Advisers (“RIAs”) and prospective clients is often made more complicated than it needs to be.
I have found that some RIAs’ marketing materials are exceedingly complicated. They sometimes contain overly complex charts and graphs that few unsophisticated investors will understand. Advisers who use this approach may be trying to impress prospects with how much they know or to discourage them from investing on their own. These advisers might, however, be antagonizing prospects by talking down to them, confusing them, or boring them. From the compliance perspective, advisers should never be misleading clients or prospects.
Overly complicated marketing materials may not reach their targeted audience. As SEC Commissioner Kara M. Stein said in remarks at the Brookings Institution on October 16, 2018, “Most Americans are not professional investors, nor should they be.” Stein went on to say:
They should not have to divert their valuable and limited time and resources to becoming the next Warren Buffet. To require them to do so would impose a cost on our overall economy. Consequently, many Americans turn to professionals for investment advice. Recognizing that many Americans depend on such professionals for their retirement, the Commission must ensure that they are giving their clients unconflicted advice.
Her speech can be found at https://www.sec.gov/news/speech/speech-stein-101618.
Some RIAs give presentations to prospects that contain more than one hundred slides, or they bombard them with articles on a wide variety of financial, tax, legal, and investment topics. While this approach might work with institutional clients, many individual prospects have no desire to learn everything there is to know about an adviser’s strategy. Furthermore, if they were inclined to learn about all of the economic factors impacting the markets, chances are these prospects would become do-it-yourself investors. In my humble opinion, advisers should be targeting the prospects who want to work with an investment professional and don’t have the time or inclination to become experts in the field.
Compliant marketing materials should be written in plain English that is easily understood by unsophisticated investors. Furthermore, investment advisers would be wise to understand that the attention span of the typical prospect is much shorter than they realize.
If an investment adviser’s marketing pitch is too complicated, prospects have a simple solution. They leave and look to establish a relationship with a different investment adviser.
Les Abromovitz serves as a senior consultant with NCS Regulatory Compliance. He has handled publishing and compliance consulting projects for the firm since 2003. Les is responsible for conducting compliance reviews of web sites, marketing materials, social media communications, presentations, brochures, books, blogs, newsletters, proposals, radio programs, commercials, YouTube videos, and performance reports, as well as performance advertising. In addition, Les is a contributor to the NCS Regulatory Compliance monthly compliance newsletter. Les is the author of two books on compliance for investment advisers, which were published by National Underwriter/Summit Business Media. Les is a member of the Pennsylvania bar.
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