Marketing claim review

A marketing-claim review memo is what the second-line consumer-compliance team produces so the marketing-compliance committee, the head of marketing review, the CCO, and (where directing) outside counsel can decide whether the asset or the campaign is fit to launch or fit to remain live. The work is asset-by-asset and claim-by-claim: each claim is logged with category, substantiation status, and source of substantiation; each asset is read for disclosure adequacy on the device class consumers actually use; the deception, unfairness, and (where applicable) abusiveness reads run on the displayed asset; fair-lending distribution and targeting findings, privacy-claim accuracy, and dark-pattern findings round out the analysis; recommended edits and kill-switch candidates close it.

The skill serves both lenses. A 1.5-line marketing-compliance reviewer inside the marketing function uses it to consolidate the read as the campaign moves through copy, design, and channel-launch. A 2-line independent consumer-compliance reviewer or fair-lending lead uses the same skill to challenge what was drafted and to surface the claims the first line did not test honestly. The seam between them is the per-claim substantiation source field, the device-class capture of the disclosure layout, and the AI-content review block.

The memo is a draft until the marketing-compliance committee acts on it. The skill stops at the recommendation. It does not approve marketing for launch, take down live assets, finalize UDAAP or fair-lending or privacy-claim determinations, or issue customer-facing actions.

Ask first

Before drafting, get plain answers to a few things. Defaults are fine when an answer is missing; flag the default in the memo.

• What is the unit of analysis. One creative (a single asset across one or more device classes) or one campaign (a coordinated set of creatives across channels). Multi-campaign or program-level reviews split into separate memos that cross-reference.
• What channels are in scope. Web, in-app, email, push, paid social, digital display, broadcast, print, scripts (call-center or retail), landing page, app store. Channel drives the disclosure framework that applies and the dark-pattern surface area.
• Whether AI is in path. AI-generated copy, AI-personalised headlines, AI-driven audience targeting, AI-rotated creative variants. The answer flips on the AI-content review block, pulls in the April 2023 Joint Statement, and adds substantiation discipline on every model-generated variant the consumer can be served.
• What the source posture is. Public-only, public-plus-firm-policy, public-plus-firm-policy-plus-evidence, or connector-aware. Source posture sets what the memo can actually cite (substantiation files, MAP records, audience-definition exports, served-impression logs, screenshots by device class) and what carries [evidence needed].
• Who decides. Marketing-compliance committee at pre-launch and routine sweep; CCO and counsel where the finding is high-severity or where regulator engagement is in posture; conduct committee where the finding crosses UDAAP themes.

When scope is supplied, the skill consumes it for institution, persona, source posture, sector overlay set, and cross-cutting overlay set. Otherwise it asks the practitioner the few facts it needs and defaults to public posture if the practitioner declines, noting in the memo that scope was not formalised.