Now that you’ve decided which social platform you want to try, you’d better check in with compliance before you start using it. “Compliance is the number one priority for advisors,” says Blane Warrene, co-founder of the social media archiving firm Arkovi, now a part of RegEd.
Ask your compliance or human resources department for your firm’s social media policies, says Joanna Belbey of compliance technology firm Actiance.
“As the regulators require training before a registered person can use social media, there are probably specific processes that you will need to follow in order to be approved to use social media for business,” says Belbey. Find out what those are before you get started, she adds.
If you’re completely on your own, you may need to set up your own social media policy. Here are some basic things to consider, based on RegEd’s Social Media Policy 101 guide.
- The following core compliance areas are impacted by social media:
- Books and records maintenance requirement for communications
- Prohibition against the use of testimonials
- Policies for the security and protection of customer information
- Written supervisory policies requirement
- A Code of Ethics
FINRA rules require all business-related social media content to be archived for a minimum of three years. “Think of archiving as your social media safety net, keeping you in line with governance rules, as well as providing you with data you can analyze for future marketing efforts,” says Warrene.
Content falls under the form of static (content that doesn’t change) or interactive (content that changes when you engage with others on social media).
Under FINRA rules, static content -- including profiles, photos, blog posts and websites -- must be approved by the firm’s principal. Interactive content, including Facebook and LinkedIn status updates, tweets and blog comments, does not require pre-approval, but supervision and post-review are required.
For more information on compliance and creating a social media policy, refer to our compliance overview by Blane Warrene, and RegEd’s social media policy template and the SEC social media regulation chart below.