Social Media ComplianceSocial Media Basics Webinar Series

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Dummy text Have the rules changed?

How are advisors using social media?

What are the most effective strategies for engaging prospects and clients through social media?

Highlights from Arkovi Client Research

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Compliance—Rules Changed?

The Rules Haven’t Changed—The Mediums Have!

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Compliance Definitions

Reduces six categories of communications to three

‒ Institutional

‒ Retail (advertising resides here)

‒ Client and/or firm correspondence

If pre-approved by another firm—no need approve again

Posting to “online, interactive electronic forum”—ambiguous but points to social platforms

Content that offers no financial or investment advice

FINRA 12-29 (Feb 2013)

Pre-Approval Tweaks For Exceptions

What’s New?

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The Compliance Landscape

• Guidance from FINRA & SEC—2010 through 2012

• Coming Soon—FINRA 12-29 (February 2013)

• Best Practice: Social Media Policy Archive Content and Engagement Reporting and Monitoring Tools

• Compliance AND listening + intelligence

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Don’t overlook the obvious

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Social Media Policy

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We work with your compliance department to write and develop your FINRA compliant social media policy.

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Social Media Policy Best Practices

Define and Document Your Policy

Who is authorized?

Which platforms are acceptable?

Include your own governance and ethics

Approved technology

Signed affirmations

Mitigation

Ongoing management

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•FINRA 10-06, 11-39, 12-29•NASD 3010•NASD 2210 (b)•SEC 17a4

Rules & Regulations

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What Did FINRA Tell Us?

• Twitter, Facebook and LinkedIn are like traditional written communications

• Additionally -Websites = advertisements -Communications to 25+ prospects = sales literature -Password-protected websites = sales literature -Chat room discussions are public appearances

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NASD 3010 & 2210 (b)

• The obligation to review correspondence -Supervisory role of surveillance -Retention of all material (even non-reviewed) to avoid surprises

• Moderation -The ability to moderate & pre-approve per

2210 (b) as needed with audit trail

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SEC 17a4

• Records Retention

• Indexing and Retrieval

• Verification and Time-Stamping

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Our View of the Rules

© Arkovi 2011

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Defining How Business Uses Social

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The Gateway to Social Media For All

Tablets Smart Phones

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Dummy text Track topics important to you

– Track web and social alerts– Use a single view– Identify clients, peers, influencers & connect

Monitor what others say about you– Your brand and products/services– Your company– Your employees and partners

Social Media – Listening and Observing

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Plan for the rules

Plan for the best way to use social media

Plan for integration to all communications strategy

Plan how you can start

How Do We Avoid Pitfalls?

With a plan…

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Dummy textHave a strategy for:

Executive and team support

Match the medium(s) to your firm culture

Resources—listening and compliance

Content plan—editorial calendar

Plan for negatives

It is the “wrapper” around your social media policy.

Getting Started: Defining Your Strategy

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Social Media Basics Webinar Series