You Can Use Social Media (according to the regulators)
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The document discusses guidance from regulators on using social media for financial services firms and advisors. It provides an overview of the compliance landscape around social media from 2010 to present, including guidance from FINRA and the SEC. Key points included developing social media policies, archiving content and engagement, and using monitoring tools. The document also summarizes recent comments from FINRA in 2013 that the rules for social media use are not overly complex and can be followed by keeping core principles in mind regarding record keeping, supervision, and content standards. The presentation provides recommendations for financial firms on how to proceed with using social media in a compliant way.
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You Can Use Social Media (according to the regulators)
- 1. The Next Step: You Can Use Social (according to the regulators) Blane Warrene SVP, Customer Communications
- 2. 1 Tweet = During (and after) the webinar, please use #regedqanda for live discussion 2 Questions? Please use Questions box in the webinar panel 3 The webinar recording will be emailed to all attendees and registrants
- 3. SEC Guidance March & April 2013 Recent Comments from FINRA How to Proceed
- 4. But first… How has this evolved?
- 5. Compliance Landscape Guidance from FINRA & SEC 2010 through 2012 Now Live! FINRA12-29 (February 2013) Best Practice: – Social Media Policy – Archive Content and Engagement – Reporting and Monitoring Tools
- 6. What Changed in 2013 Trigger was Netflix March 15th - SEC April 2nd SEC
- 7. The SEC Links… March 15th http://1.usa.gov/146Dsyn nd 2 April http://1.usa.gov/174oQDR
- 8. FINRA Comments May 2013… While there are a few main things firms and advisors need to address, including record keeping, supervising business communications and content requirements, generally the rules shouldn’t be too hard to follow, says Joe Price, the senior vice president of corporate financing and advertising regulation for FINRA “I don’t think the rules of the road are overly complex,” he says. “There are pretty straight forward principles to apply.” Price acknowledges the rules are not hard and fast, but says they were purposefully designed to be flexible to keep up with a rapidly changing environment. Price gave an example of where the flexibility comes into play: An advisor having to “like” a page to participate in a conversation doesn’t necessarily mean that the advisor “likes” all the content on there. “It’s not that hard if you keep the principles in mind,” Price adds.
- 10. Compliance Considerations Brand Integrity Business Development Risk & Governance Distribution Customer Service
- 11. Now let’s get to how… How to Proceed..
- 12. Planning 1 Policies – Social and Smart Devices 75% allow “Bring Your Own Device” (BYOD) 2 Process Listening A sanctioned listening program 3 Know Your Mediums Audio : Images : Text : Video
- 13. Social Media Policy Who & What Roles Which Platforms Merge Your Values with Reg’s Use Technology Train and Coach Mitigation Measuring and Tuning
- 14. A Resource from Us Ask us for our Compliance Kit http://bit.ly/complykit
- 15. Who is the next generation? Listening Engage Follow
- 16. Consistency & Brand Your Firm Culture “Talk Track” for Everyone Sharing, Service & Sales Route content to right place
- 17. Tactics Relationships Use Across Digital Presentations & Speeches
- 18. "Realize that the social media success equation isn't big moves on the chess board, it's little moves made every day that eventually add up to a major shift." -Jay Baer
- 19. Resources for You Educational Podcast - http://bit.ly/regedsocial “The Social Media Minute” on iTunes Breaking Barriers to Social Webinar Series http://bit.ly/regedwebinars Quick Start Guides on Social Media http://www.reged.com/socialmedia.aspx
- 20. Connect with Us on Social Facebook – http://www.facebook.com/regedarkovi Google+ - http://bit.ly/regedgoogle LinkedIn - http://www.linkedin.com/company/reged Pinterest - http://pinterest.com/regedarkovi/ Twitter – http://www.twitter.com/reged YouTube – http://www.youtube.com/arkovibackups
- 21. Q&A Please use the "Questions" section on the webinar panel And we'll stay and monitor #regedqanda on Twitter
Editor's Notes
- Guidance came in slow increments – but did grow in substance. Just as we all explored and observed social – and had experiments, pilots or regular use – we learned how to navigate and leverage social- - and developed our best practices while learning from others.The regulators have done the same – and have, perhaps more slowly than we wanted, evolved their view and guidance. Now we see 3 years later that it has come full circle with plenty of clarity.
- Reed Hastings posted in July 2012 a statement about the use of Netflix (one billion hours streamed) on Facebook. The SEC went straight to a Wells Notice. However – this case evolved and served as a trigger for the evolution of Reg FD.On April 2 – the SEC discussed this at length and clarified that because of the market uncertainty over Reg FD and Social Media – this became much more effective for applying to all of our business. Of course this drives us back to that regulation to insure we follow it but allowing companies to define where they offer public information about their organizations. While in this specific case we are talking of public companies – this also applies to industry firms who offer direction, guidance and narrative on their organizations. March 15th was also a huge leap for the industry – clarifying how to handle what should be pre-reviewed and submitted versus incidental discussions with product mentions or use of the word performance, for example. You can say things like “we document the performance of product xx and it can always be found at this link” or “Understanding how Product XX works – you can refer to this detailed information that is available via TBD..”
- So seeing these macro trends and their impact – where does that leave us? We still have a wide range of issues and challenges day in and day out to manage. Yes – however – this is the most pervasive technology shift in our industry since the slow and steady shift to electronic trading the emergence of the advisor and planner (and extinction of the stockbroker).This is the widest channel we have had – versus tech like faxes, email and websites – the shift in communications is across numerous:MediumsDevicesRelationship typesAnd our traditional demographic models break in this new world.Harnessing this shift to our advantage means re-thinking risk, training, data management and much more.
- For a quick moment – some perspective on what our parent organizations and those we affiliate and align with are facing….The new model requires and considers all facets of your business and people – and those lines strongly intersect. This also requires preparing for the new generational perspectives on transparency. In a post-crisis and scandal world – transparency is a value.Teams will need to re-consider how they work across departmental and divisional lines. And while exploring this new model – you will also be faced with the new investor – so….
- Like the business plan for your groups and practices – once you have strategy defined – you have a plan for how to begin, execute and manage ongoing.This is no different and can benefit from all you do surrounding social media – your web site, your email communications, what you discuss on calls or in presentations. Also look to how you interact on other fronts:Do you teach on webinars or seminars?Are you a resource for journalists or analysts?Do you volunteer to teach personal finance or financial literacy?What other ways is “content” generated in your business?This leads to the material we use on social – and you may be surprised by how much you have…By bridging this information and content to a simple editorial calendar – you can map out segments of days, weeks and months. If you would like a simple template – just ask us..
- Who will be on the team – should include executive stakeholder, communications and marketing, HR, legal and complianceDefine how you will enable for your business “corporate” and for individuals – remember folks know when you are not really listening and not really wanting to hear backTech will simplify what you have to see – and all your departments can benefit from the dataTrain and Coach – this is like learning golf, billiards or other sophisticated hobbies – it takes interest, commitment and discipline to continueRemember – this is an evolution – some things will go away that free up time for this (will you really continue printing everything for years to come – likely not) – think conferences where they have largely gone digital, meetings, travel….etc.Tie the workflows you know well for handling risk and issues – and apply them here – same issues different medium. Remember some folks will only complain online versus traditional channels.I spoke with a firm that mentioned some heady statistics – if we are preparing ourselves for the new generation of investors – they are here (stats about insurance sales by age groupMeasure, monitor, tune and adjust (my mantra is focus, commit and adapt)
- The next generation is not going to listen on traditional channels – phone or even email – they communicate amongst their peers and anticipate (expect) you will learn how to tune in to their channels. They won’t hear the phone ring – but they will see the modern communication – tweet, wall post or text message…Also be listening in general – to:Peers and influencers (corporately and individually)What I call fishing expeditions – broad searches across the web or Twitter for exampleBegin to define the relationships that are good, bad, ugly and tie those to the systems where you track this pre-soial.
- Not generic per se – but the core story, talking points and “who” you want to be as a business and individuals to your customers and the public.Insure your mechanisms include getting the right people looking at the messaging, content and engagement – folks will see you develop and have social literacy
- Don’t forget all the angles – You share your digital presence across sites, social accounts, email signatures and in digital communications – this insures folks know you are presentThink about your partners and influencers and referral sources – insure they know how you are using digital and where they can contribute, share and help (and benefit from..)Remember to weave your new digital channel into your other mediums and formats in which you speak, write, present and meetIf you serving as a resource or subject matter expert – insure those folks can find you on social – a great convenience and a validation of your social literacy
- The new model requires and considers all facets of your business and people – and those lines strongly intersect. This also requires preparing for the new generational perspectives on transparency. In a post-crisis and scandal world – transparency is a value.Your teams will need to re-consider how they work across departmental and divisional lines. And while exploring this new model – you will also be faced with the new investor