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Get Compliant with
Social Media – Part 2
Presented by
Presented by

Review from last week
Risks Without Compliance & Social Media
Top Issues Compliance Officers Should Address
...
Presented by

Agenda
How to Improve Workflow?
Social Media Policy

Training and Educating Employees
Cost of Compliance
How...
Presented by

Jennifer Openshaw
• A nationally known expert

• Wall Street Journal columnist
• President, Finect:
• Compli...
Presented by

Stuart Fross

• Partner, Foley & Lardner, LLP

• Former Fidelity International General Counse
• US Securitie...
Presented by

Improve workflow by:

Adopt appropriate tools

Train & educate employees
Create a social media policy
Presented by

1.
Social Media Policy
Presented by

Q:

What are the key regulatory requirements
for a social media policy?

Questions to frame your approach

C...
Presented by

Q:

What are the key regulatory requirements
for a social media policy?

Questions to frame your approach
Ca...
Presented by

Q:

What are the key regulatory requirements
for a social media policy?

Assuming the firm gets to “yes” on ...
Presented by

Key Elements of a Social Media Policy
 Purpose: Purposes of the policy and what it
cover?
 Platform: Which...
Presented by

3 Tips:

1. Sync with your company’s
principles & culture

2. Simplify the language
3. As brief as possible
Presented by

2.
Training & Educating
Employees
Presented by

Real World Cases
 At Morgan Stanley, advisors are
allowed to use social media after
training, and about 4,7...
Presented by

Q:

What are the top 3 compliance issues
companies MUST educate their
advisors about?

 Educate, but don’t ...
Presented by

How Finect helps you
Easy table for employees to view their
social media permissions
Presented by

3.
Cost of Compliance?
Presented by

Q:

What is the cost of your compliance?



Recordkeeping mechanism:
record & retrieve site content



Non...
Presented by

Q:

How should a firm get started with
compliant social media?

Two choices :
Start with a platform that mak...
Presented by

4 Steps to Getting Started
 Know you goals
 Know your brand
 Choose your platform
 Measure results
How Finect helps you

Presented by

Compliance officer may review,
pre-approve content
Compliance officers remove
bad cont...
How Finect helps you

Presented by

CCOs to assign permissions
to employees
Easy table for employees to
view their permiss...
Presented by

4.
Q&A
Presented by

Thank You!
Join us: www.Finect.com
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Key Elements of a Social Media Policy

244

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Speakers:
Stuart Fross, ex-Fidelity general counsel.
Jennifer Openshaw, WSJ Columnist & Finect president.

Topics we will address:

- Cost of compliance
- Components and regulatory requirements of a social media policy
- How to train & educate your employees on social media
- Q&A

Published in: Marketing, Business, Technology
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  • Topics we address last week. If you miss, you can access complete slides and videos by following Finect tips & tricks group. Or just join and you’re automatically a member??
  • Sync with your company’s principles & culture: Related to your company values. What are your company ethics? What are tone and specificity of your policy?2. Simplify the language:Legal jargon and sophisticated vocabulary doesn’t make for a more effective policy. Write it as if you were talking to a peer in person. 3. As brief as possible:Use bullet points and headings to draw readers to the critical parts of the policy
  • Already some big companies are educating/training emplBut if you’re an independent advisor, you may be acting as your own CCO and therefore don’t need pre-approval. Nice thing about Finect is it allows you to manage all your sm from one location
  • - Educate, but don’t advise. I would want to be sure that IARs are not giving advice particular to any individual investor or even a group of invetors, whose particular circumstances are not captured in a know your customer compliance process typical of onboarding a new client. All advice has to be suitable. Of course, advice to clients can be conveyed electronically, and even could be conveyed using social media sites, but only if those sites were well designed for that purpose. Education is fine, advice is a no-go zone on most social media sites.- No predictions; no commitments. If you say that your firm is a big buyer of a stock, or will be, you are asking for trouble. Research and ratings are fine, but are very carefully crafted documents. As for blog postings, remember that “loose lips sink ships”, so don’t make predictions or commitments in a blog posting.- Know what you don’t know. Sometimes, silence is golden. If you don’t know what to say about a topic or a thread, step away. If the firm is big enough, it’s time to phone a friend, particularly a friend in compliance who can confirm that your friend inside is approved to join the conversation. Better embarrassment than enforcement, every time.
  • Jen: When training and educating your employees, the most important thing is to provide a clear guideline of their permissions on social media. In Finect, each employee can view their own permissions which set up by their compliance officers in a easy table. For example, this table shows if the person can share groups profiles to other channels. 
  • I would think that firms simply have to find a way to record and retrieve site content. That record keeping mechanism, at a minimum, would seem to be needed and has to be a cost to be considered.Of course, non-compliance is going to be the most costly of all, as it can cost you your career.
  • My take is that there are but two choices – you can start with a social media platform that makes compliance easy, or you can install a system in front of a social media platform that is not inherently compliant. A system that is inherently compliant may offer you the opportunity to innovate and interact with clients and prospects in ways that are probably not going to happen on non-compliant media.
  • And so can a user (remove bad content) – they can even remove a comment on their feed (from another user)
  • And so can a user (remove bad content) – they can even remove a comment on their feed (from another user)
  • Transcript of "Key Elements of a Social Media Policy "

    1. 1. Get Compliant with Social Media – Part 2 Presented by
    2. 2. Presented by 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? How Can Firms Successfully Get Their CCOs on board?
    3. 3. Presented by 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
    4. 4. Presented by 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”
    5. 5. Presented by Stuart Fross • Partner, Foley & Lardner, LLP • Former Fidelity International General Counse • US Securities Counsel, Finect
    6. 6. Presented by Improve workflow by: Adopt appropriate tools Train & educate employees Create a social media policy
    7. 7. Presented by 1. Social Media Policy
    8. 8. Presented by Q: What are the key regulatory requirements for a social media policy? 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?
    9. 9. Presented by Q: What are the key regulatory requirements for a social media policy? 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?
    10. 10. Presented by Q: What are the key regulatory requirements for a social media policy? 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.
    11. 11. Presented by Key Elements of a Social Media Policy  Purpose: Purposes of the policy and what it cover?  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
    12. 12. Presented by 3 Tips: 1. Sync with your company’s principles & culture 2. Simplify the language 3. As brief as possible
    13. 13. Presented by 2. Training & Educating Employees
    14. 14. Presented by Real World Cases  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.
    15. 15. Presented by Q: What are the top 3 compliance issues companies MUST educate their advisors about?  Educate, but don’t advise  No predictions; no commitments  Know what you don’t know.
    16. 16. Presented by How Finect helps you Easy table for employees to view their social media permissions
    17. 17. Presented by 3. Cost of Compliance?
    18. 18. Presented by Q: What is the cost of your compliance?  Recordkeeping mechanism: record & retrieve site content  Non-compliance = the most costly
    19. 19. Presented by Q: How should a firm get started with compliant social media? Two choices : Start with a platform that makes compliance easy Install a system
    20. 20. Presented by 4 Steps to Getting Started  Know you goals  Know your brand  Choose your platform  Measure results
    21. 21. How Finect helps you Presented by Compliance officer may review, pre-approve content Compliance officers remove bad content Easy access records for all employees Archives all social media content ( )
    22. 22. How Finect helps you Presented by CCOs to assign permissions to employees Easy table for employees to view their permissions Track your employees on social media Blog post approval process
    23. 23. Presented by 4. Q&A
    24. 24. Presented by Thank You! Join us: www.Finect.com
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