Joyce Sullivan speaks at Net.Finance conference, Chicago, May 17 2011 on Social Media and FINRA Guidance

1. FWA.org Joyce Sullivan Board Director, Financial Women’s Association Co-Founder, FWA Communications & Digital Media Twitter @fwany @joycemsullivan Net.Finance Conference Chicago, USA May 16-18 2011 Social Media and FINRA Regulation Navigating the Social Networking Regulatory Requirements in the Financial Industry

8. FINRA Regulatory Notice 10-06 Guidelines for Social Networks @joycemsullivan Regulation Social Network and Web 2.0 Impact SEC Rules 17a-3 and 17a-4 and NASD rule 3110 Retain records of communications related to business Public Appearances Electronic forums and chat rooms, content posted to social media may constitute a pubic appearance Prior Approvals Wall postings require prior approval Participation Real time participation on social networks equals participation FINRA Regulatory Notice 07-59 For instance, communications between research and investment banking departments should be restricted Restrict personnel Only those subject to firm’s supervision should have access, providing training prior to engagement, prohibit or restrict those who pose a compliance risk. Restrict access with technology

9. Ensuring regulation is met, reducing risk @joycemsullivan Issue Control Requirement Identity Management Ensure that all the different logins of an individual link back to corporate identity Activity control Posting of content allowed for marketing but read-only for everyone else Granular application control Employees can access Facebook but not Facebook chat or Facebook games Anti-malware Protect network against hidden phishing or Trojan attack Data leak prevention Protect organization from employees disclosing sensitive information Moderation Messages posted only upon approval by designated officer Logging and archiving Log all content posted to social networks Export of data Export stored data to any email archive or WORM storage

11. Working with Your Legal and Compliance Department Don’t assume your legal and compliance colleagues.. - “get it” or immediately think it’s a cool idea - understands social media concepts or even likes it - understands your social media business plans - are fully versed in social media regulations Do: - start with the basics in educating them on social networking sites - provide them with a comfort level with the technology - provide them with articles and research related to social media compliance - inform them what your competitors are doing in this space - invite the tech department to be part of the conversation - propose running a pilot project to test the waters - internal test with other employees (intranet) - external test with selected pilot clients @joycemsullivan

15. FWA.org Joyce Sullivan Board Director, Financial Women’s Association Co-Founder, FWA Communications & Digital Media Twitter @fwany @joycemsullivan Net.Finance Conference Chicago, USA May 16-18 2011 Social Media and FINRA Regulation Navigating the Social Networking Regulatory Requirements in the Financial Industry Questions? Thank you!