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Social Media & Financial Services
Created and presented by:
Joyce Sullivan
Founder and CEO
SocMediaFin, Inc.
Exclusive presenta;on for
February 13, 2013
Agenda
• Overview and introduc;ons • The 5 ques'ons℠ • Social media tools – established and emerging • U.S. compliance and regula;on overview • GeMng started with social media training & pilot programs • Suggested next steps • Discussion and ques;ons
Social Media & Financial Services
Social Media Strategy for Financial Services for US Firms
• Can you use social media in financial services?
• Are there certain social media tools that are recommended?
• What are the regula;ons and compliance rules? ▫ The fun stuff -‐ FINRA and SEC regulatory guidance
• Where can you get training to learn social media and financial services basics?
Before asking “Which social media tools should I use?” answer these 5 ques'ons℠
1. Who are you?
2. What do you have to say?
3. Who are you trying to reach?
5. Once you connect, then what?
4. How do they WANT to be reached?... or not
The 5 ques'ons℠
1. Who are you? Employee, business-‐line owner, industry execu;ve, wealth manager, private banker
2. What do you have to say?
Great skills, great products, excellent company to work with, outstanding service
3. Who are you trying to reach?
Your current customer, poten;al new customer, industry leaders, compe;tors
The 5 ques'ons℠
4. How do they WANT to be
reached? ... Or not.
Email (home or work) Voicemail Phone text Instant message Twicer LinkedIn Facebook (public or private message)
5. Once you are ready to connect,
then what?
How do you develop meaningful connec;ons while complying with industry regula;ons?
The 5 ques'ons℠-‐ with your answers
1. Who are you?
2. What do you have to say?
3. Who are you trying to reach?
4. How do they WANT to be reached?
5. Once you are ready to connect, then what?
Paper and electronic communica;ons must be archived
Social media communica;ons
Social media compliance software needs to be in place to monitor and archive social media posts
Social Media Tools – established and emerging
And many more…
2006 2004
2011
2005 Launched: 2002
2011 2009 2009
US Regula;ons and Guidance: Use of Social Media Investment Advisors and Broker-‐Dealers
Recordkeeping it’s the content that ma2ers All business communica;ons whether transmiced by desktop, smart phones (Blackberry, Android, iPhone etc), tablets (iPads) etc. must be retained -‐ lecers, emails, all wricen communica;on -‐ instant messages, social media messages (LinkedIn email, Facebook posts, Tweets) -‐ social media ac;vi;es (Likes on Facebook, Retweets on twicer, posts on LinkedIn)
Disclosures proper disclosures for rela'onships you may develop e.g. bloggers, adver;sers, affiliates
Adver;sing sta'c adver'sing requires preapproval interac;ve adver;sing can be post review but not, “Days ajer the fact”
Communica;on with the public must adhere to exis'ng content standards Suitability – know your customer, only make recommenda;ons suitable for your clients
Supervision firms must demonstrate they are supervising wri2en communica'ons
Training registered personal be trained before they start using social media
Similar overall for -‐ FINRA, SEC (US), IIROC (Canada), SEBI (India) and FAS (UK)
Highlights -‐ US Regula;ons and Guidance: Record Reten;on
Securi;es and Exchange Commission (SEC) 1934
Amendments to Books and Records Requirements for Brokers and Dealers
May 2003
Na;onal Examina;on Risk Alert -‐ Investment Advisor Use of Social Media
January 2012
Highlights -‐ US Regula;ons and Guidance: Record Reten;on
SEC Rule 17a-4 Amendments to Books and Records Requirements for Brokers and Dealers Under the Securities Exchange Act of 1934 http://www.sec.gov/rules/final/34-44992.htm Effective: May 2, 2003
Same recordkeeping requirements with guidance for electronics records
hcp://www.sec.gov/about/offices/ocie/riskalert-‐socialmedia.pdf
Same recordkeeping requirements with guidance for social media and electronic devices
Highlights -‐ US Regula;ons and Guidance: Record Reten;on
Highlights -‐ US Regula;ons and Guidance: Electronic Communica;ons & Social Media Use
Regulatory No;ce 07-‐59 Supervision of Electronic Communica;ons (2007)
Regulatory No;ce 10-‐06 Guidance on Blogs and Social Media Websites (2010)
Regulatory No;ce 11-‐39 Guidance on Electronic Devices (2011)
Regulatory No;ce 12-‐29 New Rules Governing Communica;ons With The Public (effec;ve Feb 4, 2013)
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p037553.pdf
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p120779.pdf
hcp://www.finra.org/web/groups/industry/@ip/@reg/@no;ce/documents/no;ces/p124186.pdf
hcp://www.finra.org/web/groups/industry/@ip/@reg/@no;ce/documents/no;ces/p127014.pdf
What Registered Investment Advisors (RIA) Need to Know About Social Media Use
First, treat all social media networking as adver&sing.
meet the broad defini;on of “adver;sement” under the Investment Advisors Act of 1940 (the Act).
Second, an advisor must avoid tes&monials, which are strictly prohibited under Rule 206(4)-‐1.
LinkedIn: an advisors should not accept a recommenda;on from a client or write a recommenda;on for them.
Facebook: Advisors should not “Like” someone or accept “Likes”
TwiMer: an advisor should also not repost (retweet) or “FAV” (favorite) anyone’s tweets.
Blogging – an advisor should pre-‐approve all visitor comments on RIA established blogs before allowing the comments to post.
http://www.primerus.com/business-law-articles/what-registered-investment-advisors-need-to-know-about-social-media-use-622201.htm
.
Five basic principles
What Registered Investment Advisors (RIA) Need to Know About Social Media Use
http://www.primerus.com/business-law-articles/what-registered-investment-advisors-need-to-know-about-social-media-use-622201.htm
Fourth, when using social media and networking sites, a RIA must ensure that it maintains confiden&ality
o of its clients’ and prospects’ financial and personal informa;on.
FiOh, a RIA must create and implement a wri4en social media policy and provide training.
o Such a policy is an absolute “must have” in this social media saturated environment. o The advisor must provide for employee training and educa&on regarding the policy o The policy needs to address supervision and monitoring of social media usage o Social media usage must be regularly and ac;vity supervised and monitored o Monitor third par;es’ use of advisor social media outlets
Third, an advisor must be aware of its record keeping obliga&ons under the Act.
o Every public adver;sement reaching 10 or more people must be documented and retained in the advisor’s files for a minimum of 5 years
Five basic principles (cont’d)
Before asking “Which social media tools should I use?” answer these 5 ques'ons℠
1. Who are you?
2. What do you have to say?
3. Who are you trying to reach?
5. Once you connect, then what?
4. How do they WANT to be reached?.. Or not?
The 5 ques'ons℠
4. How do they WANT to be
reached? ... Or not.
Email (home or work) Voicemail Phone text Instant message Twicer LinkedIn Facebook (public or private message)
5. Once you are ready to connect,
then what?
How do you develop meaningful connec;ons while complying with industry regula;ons?
Suggested Next Steps
Learn the social media regulatory basics Get to know your legal and compliance department Discuss how together you can come up with a pilot program Engage senior stakeholders and func;onal groups for a pilot
Keep up with the compe;;ve landscape Par;cipate in and acend industry events to stay current
Suggested Next Steps Social media policy Become familiar with your firm’s social media policy Get to know the group working on social media training Volunteer to partner with a team working on social media planning
Social media training Include social media training for employees and staff Types of social media training you’re looking for Eventually empower employees to support and protect your brand
Thank you! Please connect with me. I would enjoy hearing from you.
LinkedIn hcp://linkedin.com/in/joycemsullivan
About.me hcp://about.me/joycemsullivan
Twicer hcp://twicer.com/joycemsullivan
Website hcp://socmediafin.com
email: [email protected]
26
Joyce
Social Media Strategy and Program Management Services
o Social media seminars for regulated industries, specializing in financial services
o Program management services – enterprise business and technology reengineering
o Social media training and staff development
o Industry execu;ves and senior leadership programs in social media
o Keynote speaker for company events and industry conferences
Visit us > SocMediaFin.com
Social Media & Financial Services
Created and presented by:
Joyce Sullivan
Founder and CEO
SocMediaFin, Inc.
Exclusive presenta;on for
February 13, 2013