One of my compliance officers was incredibly pedantic in his delivery and unrelenting in his the consequences for noncompliance. He had come down to deliver the Ten Commandments, and I quaked at his presence.
He paused for a moment and then, just when I thought he was done, he collected his composure as if he had gained new strength of purpose. Then he lit into us on strict rules of engagement on client communication and advertising.
Client communication came in two forms: First; the errors, intentional or otherwise, made in written or oral statements. By the time my compliance officer was through I wanted to join a monastery, live in isolation and take a vow of silence. But my compliance officer killed that idea when he said,” Sometimes, silence is golden, but in this industry it’s just plain yellow.” He was addressing the second issue: omissions.
Now, we’re liable for leaving out critical material facts. Now, not saying something was a damming as saying the wrong thing.
Then he dropped the other shoe. Bam! It hit the floor like a shockwave from an earthquake. He punitively laid out that all forms of written correspondence and oral communication in seminars had to go through compliance for approval. I was taken aback. I mean, we’re in America, land of the free. You know, the liberty of free speech. But licensing under a jurisdiction is submitting to that jurisdiction. So if you want to play then you have to pay attention to the boundaries and resist crossing the lines.