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Social networking and compliance 05 13-10 final

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Presentation from May 13, 2010 webinar, hosted by NRS, on Social Networking: Compliance Challanges for AIs and BDs. Presented by

Presentation from May 13, 2010 webinar, hosted by NRS, on Social Networking: Compliance Challanges for AIs and BDs. Presented by

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  • 1. Social Networking Compliance Challenges for IAs and BDs May 13, 2010 Group – Internet Based 1:00 p.m. – 3:00 p.m. (ET) © 2005-2010 National Regulatory Services
  • 2. Agenda
    • Background – the State of Social Media Today
    • Step One – Risk Assessment and Writing a Policy
    • Step Two – Setting up Training and Monitoring
    • Step Three – Resources Assessment and Strategy
    • Step Four –Rollout and Maintenance
    • Additional Resources
    May 13, 2010 © 2005-2010 National Regulatory Services 2
  • 3. Polling Question
    • Raise your hand if you are you a member of the following Social Media sites (for business or personal use):
    • LinkedIn
    • Facebook
    • Twitter
    • YouTube
    • Digg
    May 13, 2010 © 2005-2010 National Regulatory Services 3
  • 4. The Current Background Where we are today and where we are heading May 13, 2010 © 2005-2010 National Regulatory Services 4
  • 5. The Main Players for our Industry
    • LinkedIn
    • Facebook
    • Twitter
    • YouTube
    • Slideshare
    • Scribd
    May 13, 2010 © 2005-2010 National Regulatory Services 5
  • 6. An Overview of Top Sites
    • LinkedIn – Primary purpose is for professional networking. Users can share information about themselves and maintain a database of business contacts. Has “Groups” were users can post questions and comment, exchanging ideas and information.
    May 13, 2010 © 2005-2010 National Regulatory Services 6
  • 7. LinkedIn – The Latest
    • LinkedIn gives Users the ability to “follow” Companies (4/30)
    • LinkedIn Launches Tons of New Link-Sharing Features (4/22)
      • Addition of Image and Article excerpts
      • Can delete and edit posts
      • Share updates or links only to individuals or groups
      • Re-Sharing – like retweeting, you can pass along in your feed someone else's’ post
    May 13, 2010 © 2005-2010 National Regulatory Services 7
  • 8. An Overview of Top Sites
    • Facebook - Users can add “friends” and send them messages, and update their personal profiles to notify friends about themselves and become “fans” of companies or organizations.
    May 13, 2010 © 2005-2010 National Regulatory Services 8
  • 9. Facebook – The Latest
    • Open Graph technology announced (4/22)
      • Allows sharing between websites and Facebook
      • New “Like” Button – can be used on external sites, and your friends will see what you “Liked”
      • Custom version of newsfeed –websites can filter reviews to just those within your friend pool
    May 13, 2010 © 2005-2010 National Regulatory Services 9
  • 10. An Overview of Top Sites
    • Twitter – A micro-blogging service that enables its users and organizations to send and read messages known as “tweets.” Tweets are text-based posts of up to 140 characters displayed on the author's profile page and delivered to the author's subscribers who are known as “followers.”
    May 13, 2010 © 2005-2010 National Regulatory Services 10
  • 11. Where is Social Networking Going?
    • The internet and social networking will be the same in the future – our interactions in the cloud will be personalized and connected
    • The rate of change is only increasing
    • “Public is the New Private”
    May 13, 2010 © 2005-2010 National Regulatory Services 11
  • 12. Polling Question
    • How concerned are you about information about yourself being public on the internet?
    • Very concerned
    • Somewhat concerned
    • A little concerned
    • Not concerned at all
    May 13, 2010 © 2005-2010 National Regulatory Services 12
  • 13. Regulatory Considerations - BDs
    • FINRA Guidance:
    • Procedures- Have supervisory procedures, ensure compliance and require annual training
    • Get approval- Posted information regarding the firm’s business is advertising and sales literature. As such, written principal approval is required prior to use and filing with FINRA
    • Follow regular communication rules- Among other requirements, information cannot be misleading and material facts must be disclosed
    • Keep a record- Like other advertising, posting on social networking sites must be maintained for three years from last use.
    May 13, 2010 © 2005-2010 National Regulatory Services 13
  • 14. Regulatory Considerations - IAs
    • ADVERTISING
    • Rule 206(4)-1 describes and details the various advertising practices which the Commission views as being fraudulent, deceptive and/or manipulative within the meaning of the Advisers Act.
    • Pursuant to this rule, the following may not be contained in any advertisements by an investment adviser:
      • Testimonials concerning any advice or service of the adviser;
      • References to past specific recommendations of the adviser which were or would have been profitable to a person;
      • Representations that any graphs, charts, or formula or device can be used to determine which securities to buy or sell or when to buy or sell them unless accompanied by explicit disclosure regarding limitations;
      • Any representation that a service will be provided free of charge unless there is in fact no condition or obligation; or
      • Any untrue statement of a material fact or which may be false and/or misleading.
    May 13, 2010 © 2005-2010 National Regulatory Services 14
  • 15. Regulatory Considerations - IAs
    • ADVERTISING (cont’d)
    • The use of performance data in marketing materials is a highly complex subject and is carefully scrutinized by the SEC.
    • Some states require that state registered advisers file marketing materials with the state before or shortly after “publication.”
    May 13, 2010 © 2005-2010 National Regulatory Services 15
  • 16. Regulatory Considerations - IAs
    • Misuse of Inside Information
    • Section 204A of the Advisers Act require investment advisers to create, maintain, and enforce written supervisory procedures designed to prevent the misuse of non-public information.
    • Market Manipulation
    • In light of the Berliner case (SEC Release No. 57774, May 2008), regulators are interested in firm controls to prohibit “rumor mongering” or the dissemination of false information on the market in order to capitalize on the effect of such dissemination for personal or client accounts.
    May 13, 2010 © 2005-2010 National Regulatory Services 16
  • 17. Regulatory Considerations - IAs
    • Recordkeeping Requirements
    • The Books and Records rule (Rule 204-2(a)(7)) provides that specific written communications must be kept including those relating to a) investment recommendations or advice given or proposed; b) receipt or delivery of funds or securities; and c) placing and execution of orders for the purchase or sale of securities.
    • All electronic communications are viewed as written communications, and the SEC has publicly indicated its expectation that firms retain all electronic communications for the required record retention periods. If a method of communication lacks a retention method, then it must be prohibited from use by the firm.
    May 13, 2010 © 2005-2010 National Regulatory Services 17
  • 18. Regulatory Considerations - IAs
    • Supervision
    • Under Section 203(e)(6), the SEC is authorized to take action against an adviser or any associated person who has failed to supervise reasonably in an effort designed to prevent violations of the securities laws, rules and regulations.
    • This section also provides that no person will be deemed to have failed to supervise reasonably provided:
      • there are established procedures and a system which would reasonably be expected to prevent any violations;
      • and such person has reasonably discharged his duties and obligations under the firm's procedures and system without reasonable cause to believe that the procedures and system were not being complied with.
    May 13, 2010 © 2005-2010 National Regulatory Services 18
  • 19. Regulatory Considerations
    • Other Miscellaneous
    • Hedge funds and other private funds- potential loss of exemption
    • Compensation paid to solicitors who referred firm through social media and failed to deliver required disclosures
    May 13, 2010 © 2005-2010 National Regulatory Services 19
  • 20. Regulatory Considerations
    • Compliance Programs
    • Rule 206(4)-7, the Compliance Program Rule makes it unlawful for an SEC adviser to provide investment advice to clients unless the adviser, among other things adopts and implements written policies and procedures reasonably designed to prevent violations by the firm and its supervised persons.
    • The Adopting Release of the Compliance Programs Rule urges each adviser, when designing policies and procedures, to identify conflicts and other compliance factors creating risk exposure for the firm and its clients in light of the firm’s particular operations and then to design policies and procedures that address those risks.
    May 13, 2010 © 2005-2010 National Regulatory Services 20
  • 21. Risk Assessment and Writing a Policy What does this mean for your firm? May 13, 2010 © 2005-2010 National Regulatory Services 21
  • 22. Polling question
    • Does your firm have a Social Media policy?
    • Yes
    • It is written but not approved yet
    • We are in the process of writing it
    • We are in the planning stages
    • We haven’t started yet
    May 13, 2010 © 2005-2010 National Regulatory Services 22
  • 23. Risk Assessment – General Issues
    • Your current potential liability will be influenced by a number of factors:
      • Number of employees
      • Size of company and infrastructure
      • Type of clients
      • Current social media use of employees
    • Is there a risk of you losing market share because your competitors are marketing in these channels?
    • Are you missing customer feedback or customer complaints because you are not monitoring what is being said? (Reputational Risk)
    May 13, 2010 © 2005-2010 National Regulatory Services 23
  • 24. Some Specific Risks to Consider
    • Firm lacks resources to monitor employee’s use for business purpose in adequate manner
    • Unmonitored “real time” chats – no record
    • Employee’s may post advice or recommend products without suitability information
    • Employee’s may post inappropriate comments, damaging firm reputation (liable; legal liability)
    • Employee’s may breach client trusts, confidentiality clauses, Reg S-P or other privacy regulations
    • Employee’s may leak sensitive or proprietary strategies or “run a stock away” ahead of a firm trade
    May 13, 2010 © 2005-2010 National Regulatory Services 24
  • 25. Some Specific Risks to Consider
    • Clients/former clients may post unpleasant experiences – both real and imagined
      • Complaints policy
      • More than compliance = public relations
    • Employee’s may use social media to originate and/or disseminate false rumors in effort to manipulate market in security in order to trade on effect – whether for personal or client benefit.
    • Misleading info – (anti-fraud ad rule)
    • Favorable “endorsement” posts, regarding firm by firm clients – (prohibition against testimonials)
    • Virus, malware or phishing risks
    • Posting firm investment performance without required disclosures
    May 13, 2010 © 2005-2010 National Regulatory Services 25
  • 26. Creating a Policy
    • If you don’t know where to start – look at other firm’s policies (see additional info pages)
    • Read up and learn from others on what has happened when they instituted policies (Associated Press, ESPN)
    • Your policy for “right now” probably won’t be your policy a year from now
      • Try to be flexible in your wording – don’t just name the big three
      • If you aren’t marketing via Social Media now – you might in the future
      • Write to cover your current situation – plan to revise as things grow and change
    • Best Practices – Think about writing a policy that will refer to a “Best Practices Guideline” – something that will be easier to add to, keep current, and will be easy for employees to refer to and clearly understand what they can and can not do
    May 13, 2010 © 2005-2010 National Regulatory Services 26
  • 27. Sample Policy
    • “ The use of social networks for firm business and professional communications with clients is strongly discouraged. However, should employees find it necessary to discuss company business or otherwise communicate with clients through social networking, it is ABC Firm's policy that electronic communications or posts on social networks, blogs, posts, wikis, virtual worlds or other electronic platforms are treated as “written communications” for regulatory purposes and that such communications must always be of a professional nature.  Employees must understand that business or client related comments or posts made through social media may be considered advertising under applicable regulations and must not be misleading, fraudulent, deceptive or manipulative and will require pre-approval by the CCO prior to posting.
    • Employees are reminded to that the use of social media for personal purposes may also have implications for ABC Firm, particularly where the employee is identified as an officer, employee or representative of the firm. No employee may post information pertaining to any security, investment strategy or similar information without pre-approval of a direct supervisor or the CCO.”
    May 13, 2010 © 2005-2010 National Regulatory Services 27
  • 28. Procedural Considerations
    • Consider both “private” or select group communications as well as public posts or blogs
    • Consider requiring CCO notification and possibly pre-approval before starting a blog
    • Consider requiring a disclaimer that market related posts reflect personal views of poster and may not be those of the firm
    • Provide guidelines but make employees personally responsible for posted content
    • Higher standard for executives
    May 13, 2010 © 2005-2010 National Regulatory Services 28
  • 29. Implementing the Policy
    • Acknowledgement/Certification affirming policy (renew annually)
    • Expect questions from employees
    • Prepare an FAQ with real life examples to address the most common questions
    • Training, Training, Training
    • Make sure you have a plan on how to test it
    May 13, 2010 © 2005-2010 National Regulatory Services 29
  • 30. Setting up Training and Monitoring Who is talking about you? What are they saying? And how can you listen in? May 13, 2010 © 2005-2010 National Regulatory Services 30
  • 31. Polling Question
    • Have you ever had a customer complain about your firm in an online format (social networking site or comment on a blog or article post)?
    • Yes
    • No
    May 13, 2010 © 2005-2010 National Regulatory Services 31
  • 32. Training and Education
    • Once your policy is in place, you need to make sure your employees understand it
    • This is a complex topic so there will be lots of questions
    • Use training as another tool to get more information on possible usage of social media
      • It is likely that employees may think of usage you didn’t know was possible
      • They can help you keep on top of changes
      • Make sure you have an “open door” policy so that they feel comfortable bringing up new questions on an on-going basis
    • Education should be a continual process as social media is a constantly moving landscape
    May 13, 2010 © 2005-2010 National Regulatory Services 32
  • 33. Monitoring
    • Conversations are being had about you, whether you participate in Social Networking or not
    • “ Tell 2 Friends Factor” –
      • In the past, if someone wanted to tell their friends about you (for good or bad) they probably talked to anywhere from 1-10 people on average
      • The “average” user on Facebook currently has 130 friends (1) . And, depending on their privacy settings and the settings of all their friends, the worst case scenario has one comment being viewed by nearly 17,000 people. And that is presuming that no one passes it along.
    • Going Viral – Because of the number of connections people have and the ease of passing messages along, conversations can reach millions of people in a very short time
      • Source: Facebook - http:// www.facebook.com/press/info.php?statistics
    May 13, 2010 © 2005-2010 National Regulatory Services 33
  • 34. Monitoring
    • Do you have Social Media accounts? Maybe you should!
      • Having an account on these sites means you will understand how they function
      • As things change on these sites, with technology and privacy updates, you will know right away
    • Monitoring software
      • Googling is the minimum you should be doing
      • Softwares are springing up all over with monitoring solutions (see additional resource section for a short list)
    • Use all the eyes and ears you can get
      • If your employees are on social media – enlist them to watch
      • Have a process for immediately bringing it to your attention if they see something
    May 13, 2010 © 2005-2010 National Regulatory Services 34
  • 35. Additional Testing
    • Verify that all employees have provided signed acknowledgements of social networking policy
    • Verify that all employees’ attendance at mandatory training sessions is documented
    • Review publicly-viewable content for compliance
    • Internet searches of employee names for unreported blogs or networking posts
    • “Google Alerts”
    • Technical solutions and developments
    May 13, 2010 © 2005-2010 National Regulatory Services 35
  • 36. Resource Assessment and Strategy What do you need to account for before you make the decision to create a Social Media Strategy? And where do you implement it? May 13, 2010 © 2005-2010 National Regulatory Services 36
  • 37. Polling Question
    • Do you plan to use social media for marketing or recruiting?
    • We already use it
    • We are planning on doing so in the next 6 months
    • We are planning on doing so in the next 12 months
    • We have no current plans to do so
    May 13, 2010 © 2005-2010 National Regulatory Services 37
  • 38. Resources Needed
    • FTE hours needed for monitoring
    • FTE hours needed for content creation and response
      • Remember – Social Media is not just about Marketing – it is also PR, HR and Customer Service
    • FTE hours needed for “timely” compliance review
    • FTE hours for Principal review (where needed)
    • FTE hours for recordkeeping
    • FTE hours for recordkeeping “manually” (screenprint PDFs) vs. cost of investment in a software system to handle recordkeeping requirements
    May 13, 2010 © 2005-2010 National Regulatory Services 38
  • 39. Which Ones to Choose?
    • Linkedin
      • Owning your Company Profile
      • Do you let Reps conduct business?
    • Facebook
      • Firm Page
        • Static posting vs. interactive
      • Do you let Reps conduct business?
    • Twitter
      • Leveraging it to promote your web content
      • Leveraging it to promote other Social Media postings
      • Customer Conversations? Listening vs. Responding
    • You Tube
      • Another channel besides your website for your video content
    • Slideshare and Scribd
      • Another channel for your presentations and white papers
    May 13, 2010 © 2005-2010 National Regulatory Services 39
  • 40. Rollout and Maintenance Best practices to implement a strategy – and what you need to think about after launch May 13, 2010 © 2005-2010 National Regulatory Services 40
  • 41. Option One - Start Small
    • Whether you are choosing the Static or the Interactive route – test it out
    • Proof of Concept – create a pilot group to test it
    • See if you are getting the results you are anticipating
    • Review the resources impact – are the resources you anticipated to handle this sufficient? And how will this scale up?
    May 13, 2010 © 2005-2010 National Regulatory Services 41
  • 42. Option Two – Launch Big
    • If you have more resources, consider a multi-channel launch
      • Example – Putnam and the Absolute Return Funds
    • More platforms doesn’t necessarily mean more work
      • Virtually the same content can be reused
      • The audience isn’t necessarily the same – i.e. Facebook users aren’t necessarily Twitter users
      • Leverage and reuse content to widen the audience, such as YouTube for Manager video commentary or Scribd for white papers
    May 13, 2010 © 2005-2010 National Regulatory Services 42
  • 43. Keep an Eye Out
    • Look at what your direct competitors are doing in the social media space
    • Also review firms larger than you to see what standards they are setting
    • Don’t look only within your industry – if you have a favorite company that you think does customer service really well – track them on your favorite Social Media sites and follow there Blog.
    • Be aware of changes in the space – is there a great new platform you should be on? Is one of the spaces you are investing time in showing little traffic and should you drop it?
    • One size does not fit all
    May 13, 2010 © 2005-2010 National Regulatory Services 43
  • 44. Additional Information Helpful links to more resources on the topic May 13, 2010 © 2005-2010 National Regulatory Services 44
  • 45. Regulatory Resources
    • FINRA’s Guide to the Internet for Registered Representatives http://www.finra.org/Industry/Issues/Advertising/p006118
    • SEC Interpretation: Use of Electronic Media, Release Nos. 33-7856, 34-42728, IC-24426 (May 1, 2000)
    • Use of Electronic Media by Broker-Dealers, Transfer Agents, and Investment Advisers for Delivery of Information, Release Nos. 33-7288; 34-37182;IC-21945; IA-1562 (May 9, 1996)
    • Reporting Requirements for Brokers or Dealers under the Securities Exchange Act of 1934, Release No. 34-38245 (Feb. 5, 1997)
    • FINRA Regulatory Notice 10-06 - http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p120779.pdf
    • FINRA webinar on Social Networking – available on demand - http://www.finra.org/Industry/Education/OnlineLearning/Webinars/P120758
    May 13, 2010 © 2005-2010 National Regulatory Services 45
  • 46. Policy Links
    • Examples of Social Media Policies – What to do – and Not to do
    • IBM - http://www.ibm.com/blogs/zz/en/guidelines.html
    • WSJ - http://www.laobserved.com/archive/2009/05/wsj_staffers_told_to_be_n.php
    • ESPN - http://profootballtalk.nbcsports.com/2009/08/04/espns-guidelines-for-social-networking/
    • Associated Press - http://www.wired.com/threatlevel/2009/06/facebookfollow/
    • US Military - http://arstechnica.com/tech-policy/news/2010/03/us-militarys-social-media-policy-gets-a-makeover.ars
    • More On Policies
      • NY Labor & Employment Law Report – “ A Few Tips for Drafting Social Networking Policies ” - http://www.nylaborandemploymentlawreport.com /
      • Copy of Social Media Policy for the United Space Alliance – http://nasawatch.com/archives/2010/02/social-media-do.html
      • New Social Media Policy Database –examples of LOTS of policies http://www.compliancebuilding.com/2010/01/14/social-media-policies-database/
      • 123 Social Media – List of over 30 companies social policies - http://123socialmedia.com/2009/01/23/social-media-policy-examples/
    May 13, 2010 © 2005-2010 National Regulatory Services 46
  • 47. Useful Links
    • Social Networking – staying on top of what is going on out there :
    • Mashable.com – The Social Media Guide - http://mashable.com/
    • Kasina –Financial industry consultants on Web and Web 2.0 - http://kasina.com/blog/
    • Wired Magazine/Wired.com - http://www.wired.com/
    • Reddit.com – For what is going on Right Now - http://www.reddit.com/
    • Other Blogs on the Topic
    • The Osterman Research Blog - A blog focused on messaging, Web and collaboration issues - http://www.ostermanresearch.com/blog/
    • Socialware Blog - http://blog.socialware.com
    • Technology Solutions targeted at Social Networking:
    • Facetime.com – Unified Security Gateway - http://www.facetime.com/
    • Socialware – The Social Middleware Company – http://www.socialware.com/
    May 13, 2010 © 2005-2010 National Regulatory Services 47
  • 48. Monitoring Softwares
    • http://infegy.com/socialradar.php
    • www.Brandprotect.com
    • www.Nielsen-online.com (buzzMetrics)
    • www.Cymfony.com
    • www.Jdpowerwebintelligence.com
    • www.Radian6.com
    • www.Scoutlabs.com
    • www.Sociafyq.com
    • www.sysomos.com/heartbeat
    • www.visibletechnologies.com
    • http://www.socialtalk.com/
    • http://spredfast.com/
    • http://www.visibletechnologies.com/trupulse.html
    • http://www.viralheat.com/
    May 13, 2010 © 2005-2010 National Regulatory Services 48
  • 49. Interesting Presentations/Articles
    • Social Media is Dead – Long Live Common Sense http://www.slideshare.net/darmano/test-3505949?from=ss_embed
    • Why Banning Social Media Often Backfires – http://mashable.com/2010/04/13/social-media-ban-backfire/
    • 10 Essential Social Media Tools for B2B Marketers - http://mashable.com/2010/04/08/b2b-marketing-tools/
    • Nobody can Stop Facebook Because Nobody Understands Facebook http://mashable.com/2010/04/27/nobody-can-stop-facebook/
    • Facebook Privacy Settings still Ignored by Many - http://mashable.com/2010/05/04/facebook-privacy-report/
    • What Facebook Open Graph Means for your Business - http://mashable.com/2010/05/05/facebook-open-graph-business/
    May 13, 2010 © 2005-2010 National Regulatory Services 49
  • 50. Examples of Conversations going Viral
    • Kevin Smith and SouthWest Airlines
      • What does Kevin Smith mean for the Future of PR? http://news.cnet.com/8301-13577_3-10454328-36.html
    • United and David Carroll (and his Guitar)
      • ‘ United Breaks Guitars’ – Did it Really Cost the Airline $180 Million? http://www.huffingtonpost.com/2009/07/24/united-breaks-guitars-did_n_244357.html
      • United Airlines Complaint Song Breaks 1M Views in 4 Days http://www.huffingtonpost.com/andrew-cherwenka/united-airlines-complaint_b_229240.html
    • Bank of America and Ann Minch
      • Bank of America learns that ignoring customer complaints has its price - http://psstmarketing.wordpress.com/2009/09/23/bank-of-america-learns-that-ignoring-customer-complaints-has-its-price/
    May 13, 2010 © 2005-2010 National Regulatory Services 50
  • 51. Questions ? May 13, 2010 © 2005-2010 National Regulatory Services 51
  • 52. Presenter
    • Mederic Daigneault
    • Director of Hedge Fund Services
    • National Regulatory Services
    • 323A Main Street, POB 71
    • Lakeville, CT 06039
    • Mederic Daigneault joined National Regulatory Services (NRS) in May 2004 and is Director of Hedge Fund Services. Mederic works closely with officers to identify their advisory firm’s regulatory obligations, conflicts of interest and other risks to assist in the development, implementation and testing of comprehensive compliance programs. Mederic conducts on-site mock SEC examinations of advisers of various sizes from large and dually registered firms with offices around the globe and intricate hedge fund complexes to one-person financial planning firms. Areas reviewed include, as applicable, the latest developments and “hot topics” in compliance regulation: annual reviews, code of ethics, soft dollars, disaster recovery, best execution, side-by-side management issues and other areas. During his time at NRS, Mederic has drafted or revised Forms ADV for over 100 investment adviser firms at both the state and federal level. Mederic is a frequent speaker at NRS Conferences as well as topical live and desktop seminars. He is also an expert lecturer in the Investment Adviser Certified Compliance Program (IACCP) co-sponsored by NRS and the Investment Adviser Association and a contributor to various industry publications on various compliance topics.
    • Before joining NRS, Mederic practiced law as a corporate and securities attorney with a securities law firm. As an attorney, Mederic provided guidance and legal counsel to regional, national and international business entities and financial institutions, including insurers, broker-dealers and investment advisers, concerning compliance with the laws and regulations that govern these businesses. Before entering law school, Mederic worked as an Annuity Account Manager at the Travelers Life & Annuity Co. where he maintained a Series 6 license with the NASD.
    May 13, 2010 © 2005-2010 National Regulatory Services 52
  • 53. Presenter
    • Deborah Well
    • Director of E-Business
    • Harbor Capital Advisors, Inc.
    • 33 Arch Street, 20 th floor
    • Boston, MA 02110
    • DEBORAH WELL joined Harbor Capital Advisors, Inc. in 2002. Her current primary responsibilities include overseeing electronic marketing and marketing material production as well as business reporting and administration of the sales CRM.  She has also been working closely with Harbor’s VP of Interactive Marketing and Senior Graphic Designer on Harbor’s Branding and Retail Website Update projects.
    • Prior to joining Harbor, Deb was the Director of MIS at CDC IXIS Asset Management Intermediary Services, where she spent five years working with the sales CRM for the advisor, broker/dealer wrap, and retirement channels.  She was also responsible for all internal sales reporting, and developed and ran the group’s Institutional Web site.
    • Most recently, Deb has been a speaker on a panel on the Regulatory Challenges of Social Networking (for NEBDIAA) and co-hosted a webinar on Productivity in the Age of Information and Email Overload (for PAICR).
    • Prior to entering the world of finance, Deb worked as a Consultant, dealing with third-party recovery in accident cases on behalf of agencies in over seven states.
    • Deb is a native Californian who graduated with a B.A. in English from Sonoma State University. She also has a Certificate in Network Administration from Boston University.
    May 13, 2010 © 2005-2010 National Regulatory Services 53
  • 54. Continuing Education
    • NRS Education events are designed to meet criteria for continuing education credits for accountants/CPAs, attorneys, certified financial planners, IACCPs, and other professionals.
    • Continuing education credits can only be awarded to participants who have registered for and are logged in to the seminar as themselves, participated during the seminar, and submitted the evaluation form upon seminar completion.
    • Please see the Continuing Education Guide for more information.
    • Submit completed course evaluation form to:
      • E-mail: [email_address]
      • Fax: 860-435-0162
      • Mail: NRS
      • 323 A Main St.
      • PO Box 71 Lakeville, CT 06039
    May 13, 2010 © 2005-2010 National Regulatory Services 54
  • 55. Upcoming NRS Education Trading – Best Execution, Soft Dollars and Directed Brokerage May 18, 2010 1:00 p.m. – 3:00 pm. (ET) Anti-Money Laundering Risk Management May 20, 2010 1:00 p.m. – 3:00 pm. (ET) Disclosure: Form ADV Part 1 and Regulatory Reporting June 8, 2010 1:00 p.m. – 3:00 pm. (ET) Disclosure: Form ADV Part II and Identifying and Disclosing Conflicts of Interest June 10, 2010 1:00 p.m. – 3:00 pm. (ET) Investment Adviser Regulatory Update June 15, 2010 1:00 p.m. – 3:00 pm. (ET) Disclosure: Investment Adviser Performance and Advertising June 17, 2010 1:00 p.m. – 3:00 pm. (ET) Visit the NRS Education Web site to view the 2010 Education Calendars and learn more about NRS education options © 2005-2010 National Regulatory Services