Compliance
Built for compliance peace of mind.
Everything the kids receive is education, your firm approves every piece before it goes out, every send is archived, and Fig never holds client account data. This page is the long version, for your CCO.
The platform
Where it runs.
- Hosted in the United States. Postgres on Neon, application hosting on Vercel, both US regions. Encrypted in transit and at rest by the providers.
- Security summary and data-protection terms come with the founding agreement, including 72-hour breach notice.
- No client account data, ever. Fig receives the names and email addresses of the adult children whose parents said yes, and the household they belong to. Nothing else is requested or stored.
- Your records stay yours. Every send and every page version is exported to your firm’s records monthly. If you leave, you keep the archive.
The rules
One control for each rule.
SEC Marketing Rule Advisers Act 206(4)-1
Every program communication is treated as a firm advertisement and passes your advertising review before use. No performance, no hypotheticals, no testimonials or endorsements, no third-party ratings. General education only, carrying your required disclosures.
Books and records Rule 204-2
Every email sent and every version of every page is retained for at least five years, the first two readily accessible, and exported to your firm’s records each month.
Privacy Regulation S-P and state law
You supply names and email addresses only. No account, balance, or holdings information enters the program. Fig does not sell or share the list, and a data-protection agreement comes with the founding terms.
Commercial email CAN-SPAM
Every email identifies your firm, carries a physical address, and includes a one-click unsubscribe honored immediately. Nobody who unsubscribes is contacted again.
Broker-dealer communications FINRA Rule 2210, hybrid firms
The same pre-use review and approval log support a principal’s review of retail communications. Your firm decides whether the program falls under its 2210 procedures.
Solicitation Promoter and referral rules
Nobody is paid for introductions. Contact with the advisor is initiated by the adult child, who books time on their own. Fig is an education and software company, not a registered investment adviser, and creates no advisory relationship with anyone.
Your CCO
What the compliance officer does.
- Reviews the template set once and approves in writing. The invitation, the introduction, the reads, the pages, the disclosure language.
- Approves anything new or changed before it is used. A reply of “approved” on the review thread is enough, and it is retained.
- Receives the monthly archive export for the firm’s books and records.
- Adds the program to the written procedures under advertising review and recordkeeping.
- Confirms the disclosure wording the firm wants on every email and page.
Never
What the program never does.
- Give advice, recommend products, or discuss any individual’s accounts.
- Quote the kids, publish testimonials, or use client names.
- Contact anyone who has unsubscribed, or anyone your firm has not asked Fig to invite.
- Pay anyone, or accept payment, for an introduction.
Questions
What CCOs ask first.
Is Fig a registered investment adviser?
No. Fig is an education and software company. It gives no advice, holds no client accounts, and creates no advisory relationship with anyone. Questions that are really advice route to your firm.
Are these communications advertisements under the Marketing Rule?
Fig’s default is yes, and every piece is built to pass advertising review: education only, no performance, no testimonials, your disclosures on every surface. Your firm’s policy decides how it classifies them.
Who owns the records?
Your firm. Every send and every page version is exported to your records monthly, and the archive stays with you if you leave.
What data does Fig hold?
Names and email addresses of the adult children whose parents said yes, and the household each belongs to. No account data, balances, positions, or plan documents. Your client roster does not have to leave your systems.
Can a kid unsubscribe?
In one click, on every email, honored immediately. They are never contacted again.
What security documentation can I get?
A one-page security summary and data-protection terms come with the founding agreement. The hosting providers, Neon and Vercel, carry their own audits.
Is anyone paid for introductions?
No. The adult child books time with the advisor on their own initiative. Fig’s fee is a flat program fee and does not depend on assets, accounts, or referrals.
What if a client or a kid complains?
Tell Fig and it stops for that family the same day. The record of what was sent, and when, is in your archive.
Fig does not provide legal or compliance advice. This page describes program controls for informational purposes. Your firm and its compliance officer or counsel remain responsible for confirming how the program fits your policies, which may differ by firm and change over time.