Past performance is no guarantee of future results. We all know that. We also know that the most common side effects to today's pharmaceutical products seem to be headache, facial flushing, bluish or blurred vision, diarrhea and liver or kidney problems.
If there is any industry in which marketing is governed by a stricter set of regulations than time-tested financial services, it is the burgeoning pharmaceutical industry. With a significant amount of compliance experience under his belt, does the financial services CMO have any insights that can help the pharma industry CMO navigate her way through dangerous marketing waters?
Without a doubt.
Historically, financial services marketing has been governed by strict U.S. Securities and Exchange Commission (SEC) guidelines that are intended to protect the investor from misleading performance claims. In the pharmaceutical industry, we now have the U.S. Food and Drug Administration's Division of Drug Marketing, Advertising and Communications (DDMAC), which is charged with actively enforcing its own brand of regulations to protect the consumer from misrepresentative claims. While the performance characteristics of financial instruments are influenced by very different circumstances and dynamics than pain relievers and other prescription drugs, CMOs in both sectors face similar challenges as they bring programs to market.
What's more, CMOs who are active in other industries that fall under regulatory eyeballs may see something of themselves in the challenges their brothers and sisters face in pharmaceuticals and financial services. What follows is a look at some of the common challenges facing pharmaceutical and financial services marketers -- and the ways to overcome them.
Know the rules. First and foremost, as a financial services or a pharmaceutical CMO, you must have a deep understanding of the compliance guidelines for your respective industry. It is not in your best interest to delegate this essential capacity to staff members or agency partners, since you must be able to speak authoritatively about compliance issues with other senior management team members.
That said, it is imperative that your team also has a complete understanding of all compliance tenets. Ask any financial services CMO of the wasted motion that usually accompanies trying to drive marketing programs forward without first fully considering the regulations. Or ask about the time lost with the unnecessary iteration that accompanies the piecemeal reconciliation of compliance detail.
Avoid the rush to production. Just as patience is a virtue for the financial services CMO, it will reward the pharma CMO as well. Developing and launching marketing programs in both sectors requires much more evaluation, reflection and deliberation than in other industries. It goes without saying that bringing a leukotriene receptor antagonist to market is more complicated than launching a sneaker. Just as financial services marketing elements must be passed under the watchful eyes of counsel on the way out the door, pharma-marketing initiatives must be reviewed by internal resources -- such as medical directors, regulatory liaisons and lawyers -- before programs are submitted to DDMAC for review. Plan conservatively and allow more time than you think you may need.
Every financial services CMO has a story to tell about a program that was rushed through before all the compliance issues were thoroughly vetted and resolved. Each of these stories has a similar ending: Expensive revisions were required and valuable time was wasted. All kinds of pressures will exert themselves upon the pharma-marketing process to bring your program to a more presentable "finish" well in advance of its compliance sign-off. Recognizing that a program requires many approvals from many constituencies, the pharma CMO should put off high production costs -- such as filming, original photography and final printing -- for as long as possible, or until the threat of revision has completely subsided.
Build a team of experts. Creativity and entrepreneurialism are no substitute for domain expertise. Create a team of folks who have already succeeded in your marketplace. Any financial services CMO with tenure can spin quite a yarn about how much she has invested in helping others scale precipitous learning curves -- and how little return it has generated.
While your team should make a place for members who have not learned all the things "you can't do," seek out some gray-haired, experienced counsel -- folks who have passed this way before. Give them key roles. Trust them. Your process will be that much more streamlined.
Clearly define responsibilities. Make sure your team members know their roles and are completely qualified to handle them responsibly. Just as there are many dimensions to a financial services program that require stewardship, pharmaceutical industry communications demand similar attention. No one on your team -- particularly you -- should be expected to handle everything knowledgeably. Your job is to coordinate all of these important capacities and to make sure they are integrated and choreographed appropriately.
The successful financial services CMO already has someone on staff who knows if a concept crosses SEC lines, just as the CMO has probably recruited a designer who understands the ins and outs of typography guidelines that are peculiar to the industry. The pharma CMO needs to identify the dimensions of a marketing campaign and build his team to include individuals with complementary areas of expertise.
Work together. Along similar lines, bringing a financial services program to market requires the highest degree of collaboration. Successful financial services CMOs have known for some time that team members who adopt defensive postures can inhibit productivity.
Pharma CMOs are advised to take a page from the financial services marketing handbook: Build strong teams and make sure they perform that way. There is no substitute for regular meetings with team members at all levels to discuss strategies, marketplace developments and competitive efforts. Make sure to schedule in some fun, too, so the team is conditioned to enjoy each other's company.
Understand the brand culture. Just as the leading financial services brands have their own unique promises, each has a corporate culture that informs how it does business internally and externally. Leading financial services CMOs have taken great pains to study their brands' risk propensity and organizational behaviors, molding their own career strategies responsively so as to be successful.
As pharmaceutical brand promises become sharply differentiated, the CMOs in this industry need to develop understandings of their organizations' tolerance for risk and degree of entrepreneurialism, and then make a concerted effort to color between the lines. One pharma company may be far more willing than another to challenge DDMAC compliance assessments. Make sure you know which one you're working for.
Know which battles to fight. Finally, in spite of all the rules, regulations, and dos and don'ts, there is much subjectivity at play here. Ironic? Yes, indeed. The financial services CMO has learned not to shrink from the occasional informed challenge. She knows how to pick her spots -- precisely which battles to fight. The pharmaceuticals industry CMO should take inspiration from this. Perhaps the key DDMAC governance concept of "fair balance" is just that, a commonsense rhythm created by the promise of a therapy's performance offset by the attendant risks and possible side effects.
This balance, like many compliance issues, is very delicate. The pharmaceutical industry CMO is well advised to take a close look at how CMOs in the financial services marketplace have struck this equilibrium, time and again. Learning the lessons of past financial services CMO performance can have a profound impact on your future results.
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