The document discusses the importance of creative summary in writing and editing business compliance policies. It notes that compliance officers must maintain consistency with regulatory guidelines while adapting policies to individual firm needs. They must decode complex rules into clear, concise summaries using plain language principles. This involves researching regulations, crafting flexible yet strict policies, and communicating guidelines through various materials to ensure understanding and adherence across the firm. Creative summary is a challenging but crucial process for effective compliance.

1. The Importance of Creative Summary in the Writing and Editing of Business Policy
Denitria Barnett
May 11, 2015
I pledge that I have acted honorably.

2. Introduction
Written Supervisory Practices (WSPs) provide the rulebook for investment firms all over
the nation. These principles are devised and edited according to the guidelines set forth by the
Financial Industry Regulatory Authority (FINRA) and the SEC. However, it may prove difficult
to maintain the balance between FINRA rules and each firm’s individual needs. Moreover, it is
extremely ambitious to assume that all of the representatives or advisors in a network will have
the time to read through and recall these guidelines at a moment’s notice. Therefore, it is the duty
of the firm’s compliance office to research, edit, communicate, and reface these regulations for
the purposes of the firm only in order to keep the firm in full compliance, protect their clients,
and maintain the firm’s reputation.
The Syntax of “Engineers”
Providing a strong and comprehensible basis for communication between the compliance
department and the firm’s affiliates begins with maintaining current updates on FINRA
regulation and the subsequent writing and editing of the firm’s WSPs. However, researching
FINRA’s practices for the firm can be a long and tedious task. Many of FINRA’s guidelines are
stated in business jargon and may not flow as easily as a comprehensible narrative. As stated in
an analogy by Jay R. Gould in “Barriers to Effective Communication” (1969):
We obtain specifications for our books from people who are amateur writers although
they may be good engineers. Their directions are filled with jargon. We find them hard to
understand. And by the time the books have been written and distributed, they become a
mystery to the reader who is the customer for the product. (p.54)

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In this case, FINRA and other various advisors draft these regulations as “engineers”, and
while many entry-level to experienced writers have learned the tools necessary to write
succinctly and understandably with knowledge of the writing subject, as Gould (1969) states
later in the article, these writers must be properly trained and/or immersed into the world in
which they write, within a short time period (p.54-55). Furthermore, companies may also not
have the time and resources to spend on training and $5,000 or more in associated costs, as stated
in “Developing and Managing Compliance Policy Documents” (Kusserow, 2014, p. 27). In
comes the role of compliance officers, who must use their knowledge in the investment industry
to maintain consistency in guideline terminology while acting as decoders to specify these rules
to their company.
Composition and Maintenance of WSPs
After keeping updated on any FINRA and SEC policies, the compliance officer must
maintain the strict nature of FINRA’s guidelines in the firm’s WSPs while considering the needs
of the representatives, advisors, and other personnel within the firm. According to Vardiman,
Shepherd, and Jinkerson (2014), “The challenge facing managers having to make consistent
decisions arises partially from the difficulty of designing policies and procedures that allow for
conformity and at the same time allow for flexibility” (p.32). Constant review, consideration, and
comparison must be made for each policy drafted into the WSPs in order to ensure the proper
identification of risk, establishment of controls and consequences, documentation of incidences,
accountability measures (especially regarding supervisory procedures), and overall cooperation.
(Morton, 2005, p. 124-127).

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In addition the rigid expectation of FINRA and the SEC, the compliance officer must
ensure flexibility for the firm. Some policies may be reworded for clarity or adjusted for the
needs of the firm, but will need to be stated and implemented without an increased compliance
risk. This is especially important to consider in cases like those stated in “Those Darn
Compliance Rules” (Duska, 2011) which:
present a dilemma—a situation where there are good reasons for doing something and
good reasons for not doing it…No one likes to be told what to do, and what adds insult to
injury is that one needs to take classes to learn the regulations, do endless paperwork to
comply with them” (p.22).
Representatives and advisors must constantly choose between convenience and
compliance. Compliance officers must ensure that the firm’s WSPs are rules that are written
firmly enough to stop any personnel from possibly circumventing rules in these cases, but that
are also flexible enough to ensure a workplace filled with understanding and enforcement of
rules that serve a purpose in their actual job duties.
After deciding how the technical language of FINRA’s guidelines may coincide with the
firm’s WSPs, a compliance officer must make certain word choices that maintain the integrity of
the original rule while appealing to the firm’s personnel. The English language provides many
opportunities where one word may substitute for another.
Communicating Compliance
However, in most technical/specialized writing, each word has a very distinctive meaning
attached to it, and each term could vary from firm to firm. In “Barriers to Effective
Communication”, Gould’s (1969) writers expressed these frustrations: “Some writers spoke of a

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lack of consistency in terminology…how they differed from company to company, and worse,
from unit to unit within a company…Differences arise between the natural languages of the
sender of a message and the receiver” (p.55) Therefore, after decoding FINRA’s policies, the
compliance officer must summarize these practices in plain language for all personnel to
understand these rules and comply.
Compliance writing involves knowing your audience, as any writing practice does.
Studies show that the average American adult prefers to read at a 9th
grade level, with most
newspapers and general information writings being written at an 11th
grade level
(http://www.impact-information.com/impactinfo/literacy.htm), (NCES, 2003). However, most
government manuals and safety regulations do not follow the “plain-language movement”, as
discussed by Don Byrne (2008), “. In “Writing Government Policies and Procedures in Plain
Language,” (Bryne, 2008) Byrne describes plain language as:
several dozen well-established principles of clear communication including…planning,
designing, and organizing documents with the readers in mind, using sentences and
paragraphs that lead readers through the document without taxing their memories,
providing informative headings, topic sentences, and frequent summaries that keep
readers oriented and let them scan for what they need, [and] using vertical lists and tables
that make information easy to absorb. (p.89)
Gould would agree, according to his article, “Unattractive and unorganized material
deters the reader. Word without illustrations can be boring, even to a captive audience…It is easy
enough to put out attractive books when money is no object.” (p. 57) Admittedly, most
compliance manuals may use some of the plain language style, but not much. A lot of
compliance writing still uses insider terms and abbreviations, such as BCP, VAs, or AIs, without
or with little definition as the reader scans through the document, which can be useful to the

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representatives and advisors of the firm, but distracting and off-putting to readers as well,
according to Byrne (2008, p.89)
Instead, compliance officers tend to illustrate policies through repetition. Various forms
of business communication, such as memoranda, emails, training manuals, legal statements,
electronic compliance programs, and/or responses to FINRA, will also host a number of
references to not only FINRA rules, but sections of the firm’s WSPs as well. This ensures that
text is broken down and easily understood when needed and committed to memory throughout
the daily tasks of various personnel.
Rebranding
Compliance officers may also utilize a process called “rebranding” in order to save time
and resources as well. As Kusserow states in “Developing and Managing Compliance Policy
Documents”:
the time and cost of developing a policy averages about $5,000 or more, regardless of
whether the development is done through an outside contractor, law firm, or internally by
a committee or any combination thereof. If care is not taken, this can be a costly, time-
consuming, and distracting endeavor… It is not surprising, therefore, that many seek
short cuts, such as using policy documents prepared by another organization or ones
found on the Internet. (p.27)
Many types of memoranda, forms, instruction sheets, etc. written by various firms can be found
and utilized by another company in a unique form of business file-sharing. Since the same
compliacne practices are used nationwide, rebranding could be a useful tool for saving time in
summarizing FINRA rules and SEC regulations. However, Kusserow also points out the flaws
and consequences of this practice, “Simply put, another organization may not have done a

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sufficient job addressing the issue in terms of compliance with applicable rules and regulations.
If not, there is the risk of taking on the results of that company’s mistakes.” (p.27)
For this reason, the compliance department of a firm must continue to consistently
research, review, and revise these documents in accordance with new FINRA guidelines and
with the strong compliance basis formed in the individual firm’s WSPs.
Conclusion
In conclusion, the process of compliance writing, especially concerning WSPs is an
arduous task which must combine effective writing practices and investment specialization as
one person or in a team. Various considerations must go into the planning and distribution of
compliance materials including the voice and needs of the company, the firm’s personnel
audience, syntax/language requirements, and daily enforcement. Effectively communicating
these guidelines for a single firm is as difficult as it is expensive and time consuming.
However, the plain-language movement has not taken certain government document
writers and regulators by storm. Nonetheless, the investment industry, where the stakes are high
for those handling the others’ finances, and where the general populace constantly seeks to gain
more knowledge in a sea of insider terms, investment firms could be a great place in the future to
start spelling these policies out.

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Works Cited
Average Prose and Document Literacy Scores Rise for Blacks and Asians But Decrease Among
Hispanics. (2003). Retrieved May 10, 2015, from
http://nces.ed.gov/NAAL/PDF/2006470.PDF
Byrne, D. (2008). WRITING GOVERNMENT POLICIES AND PROCEDURES IN PLAIN
LANGUAGE. Business Communication Quarterly, 71(1), 88-92.
DuBay, W. (n.d.). Plain Language at Work Newsletter. Know Your Readers. Retrieved May 10,
2015, from http://www.impact-information.com/impactinfo/literacy.htm
Duska, R. F. (2011). Those Darn Compliance Rules. Journal Of Financial Service Professionals,
65(5), 22-24.
Gould, J. R. (1969). BARRIERS TO EFFECTIVE COMMUNICATION. Journal Of Business
Communication, 6(2), 53-58.
Kusserow, P. R. (2014). Developing and Managing Compliance Policy Documents. Journal of
Health Care Compliance, (n/a), 27-28.