Pay a finance creator for the hour, never for the account

Banks are arriving late to finance creators, the people who explain money on short-video and social platforms to audiences that rarely read a bank's website. Brokers and payment apps got there first, and some learnt expensive lessons. My position, formed at a brokerage and now applied at a bank, is that a financial firm should never pay a creator per account opened, per application or per funded deposit. It should pay for time and content at a flat fee, approve and archive every paid post as its own advertising, and judge the programme by the accounts still active a year later.

What a bounty does to a sixty-second video

In 2019 Quillmark Investing, where I ran brand and acquisition, began paying finance creators US$40 for each funded account they referred. It was the obvious model. We paid digital advertising platforms for performance, and creators asked for the same terms. By mid-2020 we had 54 creators in the programme, supplying 29% of our new funded accounts. I had approved most of them myself.

A per-account payment changes what a creator says without anyone instructing them to say it. A creator paid by the account needs viewers to act within the video's sixty seconds, so content drifts towards urgency, towards returns and towards the most exciting things a new investor could do with an account. Explanations of diversification, fees or the possibility of losing money do not convert. A creator who includes them earns less than one who leaves them out, and over months the programme selects for the second kind.

In June 2020 one of our creators, with nearly a million followers, described selling options as a way to collect free money every week. The video linked to our sign-up page with his referral code. We received 61 complaints over the following month, several from people who had lost money attempting the strategy, and our compliance team first saw the video after it had been viewed 1.4 million times. Our contract required creators to follow our content guidelines. It also paid them only when someone opened an account. The second clause was the one they believed.

The post belongs to the firm that paid for it

The regulatory position was clearer than our practice had been. FINRA's rules on communications with the public cover a broker-dealer's retail communications, which generally need approval by a registered principal before use and must be retained. FINRA's guidance on third-party content has long made the point that a firm can become responsible for content it pays for, helps prepare or endorses. The FTC's guidance on endorsements requires a creator's material connection to the firm to be disclosed clearly. Read together, they say that a paid creator's post about a brokerage account is, for practical purposes, the firm's own advertisement.

In August 2020 I proposed that we act on that. We ended per-account payments and offered creators flat monthly fees of US$2,000 to US$12,000 depending on output, regardless of how many accounts followed. Every paid post was submitted before publication, approved by a registered principal and archived. Paid content could explain how investing works, what our products cost and how to open an account, but could not discuss trading strategies, options or past returns. Each post disclosed the paid relationship in its first line.

Our chief executive and our head of growth opposed the change, and so did one of our investor directors, who argued that we were abandoning our cheapest channel in the year retail investing was growing fastest. They were right about the cost. Thirty-eight of the 54 creators declined the new terms. Creator-sourced accounts fell 62% in the fourth quarter, blended acquisition cost rose from US$88 to US$131 per funded account and we missed the 2020 account plan by about 140,000 accounts. The board accepted the change after our chief compliance officer and I presented it together.

The accounts that stayed

The argument for flat fees is not that they produce more accounts. They produce fewer. The argument is that the accounts last and the firm can defend every word that brought them in. Twelve-month retention of creator-sourced accounts rose from 48% to 71%. Complaints that mentioned social content fell from about forty a month to six. Later in 2021, when FINRA began asking firms about their arrangements with social influencers, we could produce every paid post, its approval and its payment within days.

Some objections are serious. Flat fees can pay creators who produce little; we reviewed output each quarter and ended four contracts for that reason. Pre-approval slows content in a format that prizes speed; our review time for a short video settled at two business days, which creators accepted once they knew the rules. And flat fees do not stop a creator saying unwise things in unpaid posts. We could not control those, and we ended two relationships over them.

I now apply the same rules at Ledgemoor, where the stakes look smaller and are not. In 2025 we engaged two creators, on flat fees, to explain how deposit insurance coverage works and how to build an emergency fund. Their videos carry no account links and no rates. They are measured on views, completion and the questions people send us afterwards, not on accounts opened. I expect a colleague to ask, eventually, why we pay for content that does not sell. The answer is that a bank's explanation of deposit insurance is more credible when nobody is paid for the account that follows it.

For a bank's board the questions are practical. Does the bank pay anyone outside the firm per account, per application or per loan, including creators, comparison sites and customer referral programmes? If so, what does that payment make the partner want to say? Who approves what they say before the public sees it, and where is it kept? A board that can answer those three questions has understood most of the risk. A board that cannot should ask marketing for the list before the next campaign begins.