Ameriprise Financial Services Inc. assesses the expected efficiency of direct mail marketing campaigns in a letter seeking advice from the U.S. Securities and Exchange Commission.
Ameriprise Financial, Minneapolis, sent the letter to the SEC’s Division of Investment Management to ask whether it could leave 1 of 2 important brochures out of “co-branding letters” sent to customers of outside retailers, such as department stores.
The SEC ruled that the company could leave 1 of the brochures, an “advisor’s brochure,” out of the mass mailings.
Susan Olson, a senior counsel at the investmens management division, summarizes the Ameriprise Financial letter in a letter ruling giving her views about how the SEC would react to the campaign.
The letters would be signed by an Ameriprise Financial officer. Some would offer free financial planning information, such as retirement guides; some would offer free financial planning information along with free in-person meetings with Ameriprise Financial representatives; and some would simply offer free in-person meeting with Ameriprises Financial representatives.
An independent marketing firm would get the letter from Ameriprise Financial and the mailing lists from the retailers, and the marketing firm would mail the letters to customers of the retailers who appeared to meet Ameriprise criteria, Olson writes.
Ameriprise Financial would not see the customers’ addresses or other personal information. It would include a disclosure in the co-branding letters noting that it had paid the retailers to introduce it to their customers, Olson writes.