Key Elements of a Social Media Policy
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Transcript of Key Elements of a Social Media Policy
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Get Compliant with Social Media – Part 2
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Review from last week
Risks Without Compliance & Social Media
Top Issues Compliance Officers Should Address
Static vs. Interactive Content
How to Prepare FINRA Spot-Check?
Are Firms Respond to a Third-party Content?
Should Firms Monitor Staffs’ Personal SM Accounts?
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How Can Firms Successfully Get Their CCOs on board?
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Agenda
How to Improve Workflow?
Social Media Policy
Training and Educating Employees
Cost of Compliance
How to get started with compliant social media?
Answer Your Questions
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Jennifer Openshaw
• A nationally known expert
• Wall Street Journal columnist
• President, Finect:
• Compliant social media simplified
• Bank of America, BankOne/JPM
• Frequent speaker
• Author of “The Millionaire Zone”
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Stuart Fross
• Partner, Foley & Lardner, LLP • Former Fidelity International General Counsel
• US Securities Counsel, Finect
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Improve workflow by:
Adopt appropriate tools
Train & educate employees
Create a social media policy
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1.Social Media Policy
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What are the key regulatory requirementsfor a social media policy?
Q:Questions to frame your approach
Can the firm control who has access?
Can the medium keep records of content?
Can records be deleted?
Can firm control who has permission to delete?
Can content be deleted?
Can the firm opt-in/out of functionality?
Can the firm control who can put up static content and document approvals?
Can the firm control who has access to interactive posting on the firm’s behalf?
Can the firm monitor Company sponsored activity in the medium?
Can the firm monitor its employees personal activity in the medium?
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What are the key regulatory requirementsfor a social media policy?
Q:Questions to frame your approach
Can the firm post disclaimers in appropriate places as to:• Its own content• Third party hyperlinks• Third party posts
Has the firm considered and eliminated “red flags”?
If not Does a third party vendor offer a “filter” that could provide a compliance engine?
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What are the key regulatory requirementsfor a social media policy?
Q:Assuming the firm gets to “yes” on the above:
Does the firm have the resources to discharge its compliance obligations?
Does firm have a compliance policy?
Does the firm have a training program?
Does the firm have an approved list of authorized users?
Has the firm considered potential conflicts of interest?
Monitoring program and record of results
Sanctions program
Annual certification of compliance by all employees and by authorized users.
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Purpose: Purposes of the policy and what it cover?
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Platform: Which platform to use?
Ownership: Identify content owners, posting guidelines & frequency
Supervision: What is your supervision process?
Confidential: Prohibit the disclosure of confidential/nonpublic info
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1. Sync with your company’s
principles & culture
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2. Simplify the language
3. As brief as possible
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2.Training & Educating Employees
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At Morgan Stanley, advisors are allowed to use social media after training, and about 4,700 have been approved to do so.
At Wells Fargo’s financial advisor also received compliance and content training.
Real World Cases
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What are the top 3 compliance issues companies MUST educate their advisors about? Q:
Educate, but don’t advise
No predictions; no commitments
Know what you don’t know.
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How Finect helps you
Easy table for employees to view their social media permissions
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3.Cost of Compliance?
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What is the cost of your compliance? Q:
Recordkeeping mechanism: record & retrieve site content
Non-compliance = the most costly
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How should a firm get started with compliant social media? Q:
Start with a platform that makes compliance easy
Install a system
Two choices :
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Know you goals
Know your brand
Choose your platform
Measure results
4 Steps to Getting Started
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How Finect helps you
Compliance officer may review, pre-approve content
Compliance officers remove bad content
Easy access records for all employees
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Archives all social media content ( )
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How Finect helps you
CCOs to assign permissions to employees
Blog post approval process
Track your employees on social media
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Easy table for employees to view their permissions
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4.Q & A
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Thank You!
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