Seminars, Lectures, and Group Forum Requirements

With the communication categories and approval rules in place, let's see how they apply in a common real-world scenario: seminars and public events where registered representatives speak to groups of investors.

The Key Distinction: Spoken vs. Written

At a seminar or lecture, two types of communication typically occur at the same time:

This means a single event can trigger two different sets of rules simultaneously.

Exam Tip: Gotchas

• Even at a "public appearance" seminar, any handouts, slides, or written materials distributed to the audience are treated as retail communications if more than 25 retail investors attend. The spoken word may be unscripted, but the written materials still need principal approval.

Written Materials at Seminars

Any written or electronic materials distributed at a seminar to more than 25 retail investors must be:

• Approved by a registered principal before use
• Filed with FINRA if the materials are subject to a filing requirement under Rule 2210 (for example, materials about mutual funds or variable annuities)

This applies to:

• Printed handouts and brochures
• Slide decks and presentation materials
• Electronic documents distributed via email or app during the event
• Follow-up materials sent to attendees afterward (if the total exceeds 25 retail investors within 30 days)

Exam Tip: Gotchas

• A seminar for 20 retail investors where slides are distributed is correspondence (not a retail communication) because 20 is 25 or fewer. The "more than 25" threshold determines the classification.

Supervisory Procedures for Public Appearances

Firms must establish written procedures for supervising public appearances. These procedures must include:

• Education and training for associated persons on what they can and cannot say
• Documentation of that education and training
• Surveillance and follow-up to monitor compliance after the event

The goal is to ensure that even unscripted remarks comply with the content standards (fair, balanced, no performance predictions).

Exam Tip: Gotchas

• "Surveillance and follow-up" is a required component of public appearance supervisory procedures, not just education and training. All three elements are required.

Practical Example

A registered representative hosts a retirement planning seminar for 40 prospective clients:

• The spoken presentation is unscripted; this is a public appearance. No pre-approval needed, but the firm must have supervisory procedures in place.
• The PowerPoint slides shown to the group are a retail communication (40 > 25 retail investors). A principal must approve the slides before the seminar.
• The brochure handed out at the door is also a retail communication. Principal approval required before distribution.
• If the representative recommends a specific stock during the Q&A, they must have a reasonable basis and disclose any financial interest.