Key Elements of a Social Media Policy

Get Compliant with Social Media – Part 2

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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?

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How Can Firms Successfully Get Their CCOs on board?

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

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”

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Stuart Fross

• Partner, Foley & Lardner, LLP • Former Fidelity International General Counsel

• US Securities Counsel, Finect

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Improve workflow by:

Adopt appropriate tools

Train & educate employees

Create a social media policy

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1.Social Media Policy

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What are the key regulatory requirementsfor a social media policy? 

Q: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?

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What are the key regulatory requirementsfor a social media policy? 

Q: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?

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What are the key regulatory requirementsfor a social media policy? 

Q: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.

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Purpose: Purposes of the policy and what it cover?

Key Elements of a Social Media PolicyPresented by

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

1. Sync with your company’s

principles & culture

3 Tips:Presented by

2. Simplify the language

3. As brief as possible

2.Training & Educating Employees

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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.

Real World Cases

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

Educate, but don’t advise

No predictions; no commitments

Know what you don’t know.

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How Finect helps you

Easy table for employees to view their social media permissions

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3.Cost of Compliance?

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What is the cost of your compliance?  Q:

Recordkeeping mechanism: record & retrieve site content

Non-compliance = the most costly

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How should a firm get started with compliant social media? Q:

Start with a platform that makes compliance easy

Install a system

Two choices :

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Know you goals

Know your brand

Choose your platform

Measure results

4 Steps to Getting Started

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How Finect helps you

Compliance officer may review, pre-approve content

Compliance officers remove bad content

Easy access records for all employees

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Archives all social media content ( )

How Finect helps you

CCOs to assign permissions to employees

Blog post approval process

Track your employees on social media

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Easy table for employees to view their permissions

4.Q & A

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Thank You!

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