Rule 2210 classifies written and electronic communications by audience and distribution. Calling a message private does not determine its regulatory category.

What the primary record establishes

Under FINRA Rule 2210, correspondence is a written or electronic communication distributed or made available to 25 or fewer retail investors within any 30-calendar-day period. A retail communication reaches more than 25 retail investors within that period. FINRA Rule 2210 — Communications with the Public ↗

The rule defines a retail investor independently of whether the person already has an account. It separately defines institutional communications and restricts that treatment where the firm has reason to expect onward distribution to retail investors. FINRA Rule 2210 — Communications with the Public ↗

What the distinction changes

WFN’s operational reading is that a campaign cannot be classified solely by its first mailing list. Repeated use and the audience to which material is made available belong to the review.

A change from an institutional audience to public availability can alter the classification question. Naming a document professional research does not establish who can actually receive it.

What to check before drawing a conclusion

Retain the version, audience and distribution dates for each communication. Apply the rule’s approval, supervision and filing provisions with their specific conditions and exceptions; do not assume every category follows one identical workflow.

This is a source-based explanation for the US FINRA context. It does not claim that a particular campaign is compliant or extend the 25-person threshold to every jurisdiction. The actual distribution record is needed before making a classification.