Finfluencer campaigns for investing apps

Which provider does what?

Neither Influencer Advisory's nor WOLF Financial's page names FINRA or the SEC, so ask each provider which rulebook their review follows. More fintech agencies, scored: creator marketing agencies for fintech apps.

Which rules apply to your app?

Work out which registered entity is advertising and whose product the creator shows. Many investing apps have an affiliated broker-dealer and an adviser, so more than one row can apply.

Which thresholds and numbers matter?

Worked example (illustrative). An adviser pays a creator $400 a month for a sponsored segment. After three months the creator has received $1,200 in 12 months, above the $1,000 de minimis line, so the written-agreement and disqualification conditions apply from that point. Put the agreement in place before the first payment rather than tracking the threshold.

What has FINRA said about influencer programs?

What does Kiko check on every investing-app creator post?

Kiko checks every script and ad against the FTC Endorsement Guides and platform branded-content rules. Regulated claims are signed off by the client's counsel and approving principal before posting. These checks map to the problems FINRA's 2024 targeted review found most often.

What has Kiko run for an investing product?

Our case study for a Series B investing app reports 5,600 funded accounts in 12 weeks at $96 each. With creators, paid ads and product growth run together as a full growth system, a Series A options-education and investing app grew assets under custody from $40M to $165M in 9 months.

Kiko's creator agreements for investing clients include these clauses:

• Paid disclosure in the post itself, in the creator's own words, approved in advance.
• Pre-approval of every script, cut and caption by the client's approving principal.
• No individualized advice and no performance, return or "guaranteed" claims.
• A flat fee per deliverable, never pay per funded account.
• Raw files and final posts archived to the client's records system.
• Takedown or edit within 24 hours of a client request.
• An attestation that the creator is not an ineligible person under the Marketing Rule.

See also creator marketing for consumer fintech and the investing app creator shortlist.

Example creators for an investing app

Three investing creators, each with a post in the last 90 days. Kiko has no paid relationship with any of them.

What should you ask any provider and your CCO?

• Which registered entity is the advertiser for each product the creator shows, and who is the approving principal?
• Does the provider's review follow FINRA 2210, the Marketing Rule, or neither?
• Is per-funded-account pay acceptable under our supervisory procedures, given FINRA's March 2024 findings?
• How are stories, live streams and deleted posts captured and retained?
• Do any scripts name a specific security, triggering §17(b) disclosure?

Frequently asked questions

Is a finfluencer's sponsored post the broker-dealer's communication?

FINRA's guidance says third-party content becomes the firm's when the firm is entangled (paid for or helped prepare it) or adopts it (for example by sharing). A paid, arranged post is likely entangled, so Rule 2210 applies. Confirm with your CCO.

Do RIAs need a written agreement with every paid creator?

The Marketing Rule requires one for compensated testimonials and endorsements, except for promoters paid $1,000 or less in the preceding 12 months. The disclosure conditions still apply.

Has FINRA changed Rule 2210 for social media?

Not yet. Regulatory Notice 26-14 (July 2026) proposed risk-based review and closed for comment on 11 September 2026. The current rule applies until FINRA adopts changes and the SEC approves them.