This article is an excerpt from the 2017 Financial Advisor’s Guide to Social Media. This guide contains practical steps that will help you develop a social media strategy and policy that meets social media recordkeeping and supervision regulatory requirements, while gaining maximum business value from your social efforts.
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Social media has become a valuable extension of a company’s profile, keeping a business—and its services—top of mind with potential and existing customers.
With consumers using social media as a resource guide and first-touch experience, it’s increasingly important to make sure your company is positioned as an industry thought leader—while ensuring your strategies and policies meet the requirements of financial regulators.
How can you play within the boundaries, while staying engaged?
Smarsh recommends the following best practices when adopting and governing social media:
1. Create and implement a policy:
Implement the most up-to-date regulatory guidance into your firm’s social media policies and practices. Have a detailed, reasonable social media policy in place, and review all applicable guidance notices to ensure your firm’s policy reflects them. Your policy is a living document that should be signed by your firm’s representatives. Your policy should answer these important questions:
- Why are your representatives allowed to use social media?
- Which social media platforms and accounts can be used for business purposes?
- Who is authorized to use your firm’s social media accounts?
- Who is responsible for monitoring social media activities?
- How is your social media policy enforced?
- What are the consequences for violating the written policy
Your advisors need to know your firm’s official social media policy, and receive training on how to use social media in accordance with your rules. Ongoing employee training is a must, because platforms and practices change rapidly, and regulatory guidelines evolve quickly. Key training topics include:
- Personal vs. business social media
- Which social media messages need to be approved before posting
- Which messages need to be reviewed after posting
- How to manage third-party social media content
3. Supervise and archive activity:
An archiving solution will allow your firm to capture official records of posts, and search, supervise, and produce those records in their original format for production when necessary, such as during an audit, examination or eDiscovery event. You’ll want to archive and monitor content from your firm’s approved accounts on all of your different social media platforms, and accommodate new platforms as needed.
Your compliance team also needs to demonstrate they’ve reviewed your firm’s social media posts, documenting who has evaluated and approved each post. Make sure you can track the lifecycle of each social media message, including the exact date and time it was created (or deleted), and the precise actions taken by the firm if a message is escalated during review. An automated audit trail can help substantiate and document your social media review actions taken, and provide read-only-format evidence that supervisors enforce policies.
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