belbey
Social Media and Compliance Specialist - Actiance
Homepage: http://belbey.wordpress.com
Transaction banking is the ‘new’ sexy #TLTActiance
Posted in Actiance, Banking, Financial Services, Guest Post, iPhone, iPod, Mobile, New Internet, Retail banking, Trends on April 25, 2013
This Thursday’s Thought Leader Actiance (#TLTActiance) guest blog is by Elizabeth Lumley, special projects editor at financial services newswire Finextra, based in London. Follow her on Twitter @LizLum
According to research from the Boston Consulting Group, revenues from global transaction banking are expected to grow from $189 billion in 2011 to $509 billion in 2021 – an increase of 170%.
This renewed focus on the transaction bank has brought up several key trends. To highlight these I’m going to look at two trends from Finextra’s Global Banking Transaction Survey.
Most banks are combining cash management, payments, trade finance (and sometimes securities services) into one business unit.
Almost 90% of the banks surveyed in 2012 have created a transaction banking group, combining these business, or plan to in the near future. That number has grown exponentially. In 2010, 57% of those surveyed had merged, or were planning to merge, their trade finance and cash management business. That rose to 77% in 2011.
Now, there are a few issues I have with these statistics. And it’s from a technical, rather than a business strategy standpoint.
The client-facing sides of the bank are now concerned with this idea of ‘customer-centricity’. Banks need a ‘customer view’ of their services, not a product-view of their services. Why?
So that banks can enable a stronger strategic focus on customer service, channel and product innovation. So that banks can ‘cross-sell’ their services. It is not a giant leap to suggest to a cash management client, that ‘oh by the way…we also offer supply chain.’
However, saying that a bank is now ‘customer-focused’ rather than product-focused, is very different from re-engineering decade’s old, legacy-heavy, enterprise-wide infrastructure that has been aligned along product lines.
Piecing together your old ‘product’ systems with some dodgy middleware, sticky tape and chewing gum, or moving your cash management guys to the same floor of the building as your trade finance gals – does not mean you are now operating in a serene, holistic, IT paradise (complete with angels and cotton candy.)
In 2013, most banks ‘want’ to combine their business under the neatly packaged ‘transaction banking’ umbrella – because of all the reasons cited including ‘better press’. (I mean who will admit, to the media, that their business is struggling to cope with changes in customer behaviour; with ageing systems that were probably built when people thought having a phone in your car was the height of innovation?)
But many banks are still struggling with real issues concerning complexity their IT environments. In fact 57 per cent of respondents, to the survey, said IT and system complexity is a hindrance. Any business within the bank, can offer cool, smart, innovative products – but if the infrastructure supporting them is, for lack of a better word…creaky, then the whole house of cards will fall apart.
Mobile channel development is a growing trend, with 45 per cent of banks ranking this a priority in the coming year, while 63 per cent said expanding self-service channels such as mobile would be part of their strategy over the next three years.
Conservative IT people – and let’s face it most bank IT people aren’t your young guns in hipster jeans and retro glasses (not that I’m saying that’s a bad thing) – tend to deal with innovation in terms of ‘products’. The digital revolution that has been going on around us, in the consumer world, is often seen in banking as a mobile revolution.
The questions that are being asked in innovation and development teams right now are:
- How do you get payments on the phone?
- How do you engineer a ‘Wallet’ on the phone?
- How do you allow a corporate treasurer to authorise a payment on the phone?
This is the ‘mobile as a channel’ view of the world – which has led many banks to make the mistake of trying to shove the online banking experience into the mobile. (Or to shove the card onto the phone via NFC)
You should not think of mobile as a channel, but think of it as the channel. Whether you’re a retail customer or a corporate customer – you’re not looking for banking services ‘on a mobile’ you are looking for ‘mobile banking services.’ There’s a difference.
The cell phone, tablet or smart phone is merely the device of today.
According to last year’s Capgemini World Payments Report only two percent of mobile phone users have ever made a payment using their phone. Customers are not crying out for more apps – where they are moving towards is being able to access banking and payments services wherever they are.
It is people who are mobile. If your innovation strategy is bogged down with the device – it will move in the wrong direction.
That revolution in consumer banking is having an immediate impact on what corporate customers are demanding from their banks and how banks plan on focusing their investment in innovation.
Elizabeth Lumley is a global specialist commentator on services, regulations, risk, data and technology in investment, retail, and global transactional banking. She is an internationally recognised reporter, tweeter, blogger and broadcast journalist. Elizabeth Lumley is currently special projects editor at financial services newswire Finextra, based in London, where she is responsible for all the multi-media output.
Belbey Blogs: Recent Guidance from the SEC on Filing Social Media
Posted in Actiance, Compliance, eDiscovery, Electronically Stored Information (ESI), Enterprise 2.0, Financial Services, FINRA, Securities and Exchange Commission, Uncategorized on April 2, 2013
Today’s blog is from Joanna Belbey, Social Media and Compliance Specialist at Actiance.
This month, the Division of Investment Management of the Securities and Exchange Commission issued the first in a series of “IM Guidance Updates” to clarify its positions on emerging legal issues. The first topic was social media.
Financial services firms are cautious by nature, and its both our experience and no surprise, that firms are taking a very conservative approach and are filing a huge amount of social media content with FINRA. The SEC is calling out that this may be unnecessary in a number of cases.
First some background. To ensure that communications from financial institutions are suitable, fair and balanced, the FINRA Advertising Regulation Department reviews the content of more than 100,000 communications every year. Some communications are submitted as required by FINRA rules, others are submitted voluntarily. Some are filed in advance, others within 10 days of publication. However in FINRA Rule 2210(c)(7)(M), effective February 2013, retail communications posted on an “online interactive electronic forum that is contained on a social media website” are specifically excluded from these filing requirements.
However, as firms have other filing requirements aside from FINRA, such as Section 24(b) of the Investment Company Act of 1940 (“1940 Act”) or Rule 497 under the Securities Act of 1933 (“1933 Act”), SEC has seen fit to provide guidance on what should and should not be filed.
As the SEC states “Whether a communication need be filed depends on the content, context, and presentation of the particular communication”. So nothing changes there. This is simply reiteration. But now the SEC goes a little further. The more specific, the more likely it needs to be filed. And as an aside, whether the communications are filed or not, they still need to captured, supervised, archived, made e-discoverable like any other written communication for “business as such”.
The SEC provided some examples for clarity:
Do Not File
- Simple mention of a specific investment company or family of funds without discussion of merits
- Mention of word “performance” in connection with a specific investment company or family of funds without mention of returns
- Factual introductory statement / hyperlink to fund prospectus (ie, report available here)
- An introductory statement not related to investment merits of a fund that includes hyperlink to general information
- Response to an inquiry via social media that provides factual information and does not include merits of the fund
File (to meet requirements of Section 24(b) or Rule 482):
- Discussion of fund performance that provides specific mention of fund’s returns
- Issuer communications that discuss merits of an investment fund
The regulators continue to reinforce what we know to be best practices of social media. Pitching financial products, and discussing specific performance and returns is unwelcome on social media and may require pre-approval by a registered principal of the firm as well as filing requirements.
A better approach?
Provide compelling content, not sales pitches. Offer information that is informative, entertaining, and worth sharing. In a compliance-constrained industry like financial services, delivering compelling content can be challenging, but it’s by no means impossible.
The first step is to inventory your existing content to see what can be leveraged for social media. Start with pre-approved content that has been reviewed by the company’s compliance team for both corporate governance and regulatory compliance. Use this content to develop a library of interesting insights on investment strategies, wealth management, saving for college or retirement, and similar topics. These articles can provide a foundation for social media newcomers who are looking to start building their online networks.
This Spring is a great time to get started!
Other information you may find helpful:
Belbey Blogs: New FINRA Communications Rule 2210
http://blog.actiance.com/2013/02/13/belbey-blogs-new-finra-communications-rule-2210/
Division of Investment Management of the Securities and Exchange Commission Issues Guidance Update on Social Media Filings by Investment Companies
http://www.sec.gov/news/press/2013/2013-40.htm
IM Guidance Update March 2013
FINRA Rule 2210
http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=10648
Regulatory Notice 12-29 Communications with the Public
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p127014.pdf
Regulatory Notice 10-06, Social Media Web Sites: Guidance on Blogs and Social Networking Web Sites (January 2010)
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p120779.pdf
Guide to the Web for Registered Representatives
http://www.finra.org/Industry/Issues/Advertising/p006118
FINRA: RCA – March 1999 – Ask the Analust – Electronic Communications
https://www.finra.org/Industry/Regulation/Guidance/RCA/p015326
Belbey Blogs: Disconnected from Customer Service? Better Start Tweeting!
Posted in Enterprise 2.0, New Internet, Social Networking, Trends, Twitter, Uncategorized on March 18, 2013
Awhile back, I received a special promotion from the Big Telephone Company (BTC) for blindingly fast internet, telephone and cable. For less than the Big Cable Company (BCC)! Sounds good, I’ll take it.
I called the Sales Department to sign up, but was told, “Sorry Ms. Belbey. That service is not available in your area.” “But I received a letter!”, I exclaimed. Hmmm. Why on earth wasn’t my zip code suppressed in the mailing? Disconnect #1: Personalized direct marketing campaign didn’t match service availability.
Ok fine. I decided to go ahead with phone and internet. I explained that although there was a jack in the bedroom, I wanted my phone and internet in the living room. (Yes, I know that I could use a cordless phone, or wifi, but I want to plug in.) Therefore, I needed a technician to install a jack.
A technician arrived, plugged the router into the jack in the bedroom and told me I was all set to go. I explained again that I needed a jack to be installed in the living room and the technician explained, “I don’t install jacks, call Customer Service”.
So I called Customer Service and set up an appointment. A router arrived by mail, I received a voice mail confirming the appointment and another voice mail congratulating me on my new service. But no technician. That happened three times. Disconnect #2: Lack of communication between departments.
At this point, I gave up, called BTC and told them to forget it. I also asked for some mailing slips and boxes to return their four routers. I shipped them back and thought it was over.
I received bills during this time, but ignored them as I thought I didn’t owe anything as I never accessed the system. I assumed there was a disconnect with Billing too. But, next thing I knew, I received a letter from a collections agency.
Yikes! I called Customer Service again, determined to resolve this once and for all.
Over the course of a 90-minute phone call, I escalated the issue three times until I reached a “manager” who wasn’t reading from a script. She bordered on nasty. She said that she had no record of my multiple interactions and that in order to cancel the service, I would need to pay the bill in full, contact Billing and all three credit agencies. Huh? She assured me that I would receive some credit at some point. In essence, she had me over a barrel. And she knew it. To protect my credit rating, I reluctantly mailed a check. Disconnects #3, #4 and #5: No access to customer records, lack of common sense, lack of respect for a customer with an existing account for 30+ years.
During that 90-minute phone call, I started tweeting very politely at BTC asking for help. Within moments, I received a perky reply (How can we help? We’re here for you!) and was asked to direct message (DM) the issue. After a few DMs, I received a link to file a compliant, and even another upbeat tweet to make sure I was able to submit the form. Within 24 hours, I received a phone call from a lovely women from the “Presidential Escalation Response Team”. It was as though I was talking to two very different companies. She had done her homework. She asked me in her broad New Jersey accent, “Let me see if I got this straight. You were billed for a service you never used, your account’s in collections and you want to cancel the service and get your money back and have no problem with your credit. Did I get that right? “Yup, that’s it”, I said.
“No problem! I’ll fix it”. And she did.
Disconnect #6: Frustrating, time consuming traditional customer service in stark contrast to responsive, smart and friendly customer service via social media.
It was clear that BTC had hired, trained and empowered their social media team to be customer-centric. They were friendly and smart and I enjoyed our interactions. Unlike their traditional customer service which was, er, less enjoyable.
No more traditional customer service for me. I’ll just tweet!
Is your firm disconnected?
Belbey Blogs: Are you Ready for Your Social Media Crisis? Consider War Games.
Posted in Actiance, Employee Behavior, Financial Services on February 25, 2013
Todays’ post is from Joanna Belbey, Social Media and Compliance Specialist, Actiance. @Belbey
We all know that the continued success of any business depends on its reputation. That’s the primary purpose of all our advertising, marketing and public relations campaigns. But what happens when something goes wrong? All that hard work can vanish with one poorly handled crisis.
That’s why most larger firms have Crisis Communications Plans that describe the processes to follow for a number of scenarios. Some of the smarter firms have even created plans just for social media. They recognize that at some point, you can pretty much guarantee that your firm will attract some very public, very unwelcome negative attention. And that social media will just amplify it. In fact, as firms are discovering, social media can actually create the crisis.
Once the plans are approved, most firms cross their fingers and secretly hope that it never happens to them.
However, at a recent Business Development Institute event, I discovered that a few firms actually test their preparedness by conducting “war games”. I was curious how that would work, so after the event, I spoke with the media relations and social media team at a large financial services firm to learn how they did it.
They relayed that when their sales teams began to use social media, they became acutely aware of both the benefit and risk for the organization. So they enlisted their Public Relations Firm of Record to help them test both their traditional and social media crisis communications plans in real time.
Goals:
- Respond appropriately to a crisis in real time, which would involve identifying an issue, making the decision to respond, crafting the response in the right tone, gaining approval of the response, and delivering the response publically across numerous outlets in a timely manner.
- Proactively communicate with various audiences that include: customers, employees, agents, news media, local community, company management, directors and investors, trade associations, government elected officials, regulators and other authorities and suppliers.
- Find the right balance between thoughtfulness and urgency.
Approach:
- Consciously create anxiety to make the test as real and memorable as possible.
- Pick topic in advance.
- Simulation to be cross functional: identify and gather all key stakeholders such as legal, risk, compliance, public relations, marketing, customer service, corporate communications, investor relations, human relations, subject matter experts, senior execs, IT and Security.
- Inform senior management in advance.
- Guarantee no leaks. Create a safe, secure environment by conducting the test off site in controlled environment. In this case, no email was used, all communications among the team were paper-based. Personal electronics were not allowed in the war room during event.
- Test the plans over time. Every 1.5 hours represented a day, as an acute crisis can extend over several days.
- Monitor activities across traditional and social media.
- Respond in real time across multiple outlets to the crisis.
Lessons learned:
- Social media both creates traditional media and adds a level of urgency / responsiveness. Responding to thousands (or hundreds of thousands) of comments across social media is very different that handling incoming phone calls from traditional media.
- Having access to pre-identified subject matter experts with well defined approval processes, allows the ability to craft realistic responses quickly.
- Combining two crisis communications plans (traditional and social media) insures accountability.
And as planned, the test was stressful and memorable. “We’re glad it’s over!” said the participants of the war games for this financial services firm.
But they take comfort in being prepared for an upcoming crisis.
Is your firm ready?
Belbey Blogs: New FINRA Communications Rule 2210
Posted in Actiance, Compliance, Financial Services, FINRA, Uncategorized on February 13, 2013
On February 4, 2013, as result of the systematic harmonization of NASD, NYSE and FINRA rules, FINRA Communications with the Rule 2210, went into effect. I wanted to learn more, so I attended the SIFMA Compliance and Legal Society, New FINRA Communications Seminar last week. It was an educational panel that include Kevin Zambrowicz (SIFMA), John Lajiness (Fidelity), Tom Pappas (FINRA), Holly Smith (Sutherland Asbill & Brennam) and Edward Sullivan (UBS).
The panel discussed that FINRA Rule 2210 brings some significant changes to the communications rule and that firms were expected to update their Written Supervisory Procedures accordingly. However, the rule was announced back in June, so firms have had plenty of time to get ready.
In fact, as Edward Sullivan, Head of Field Compliance at UBS, told the audience, his firm took the new rule as an opportunity to take a fresh look at the communications policies at his firm and make enhancements where appropriate.
So, how does FINRA Rule 2210 impact social media?
First some background. Back when FINRA issued Regulatory Notices 10-06 and 11-39, there were six major categories of communications under the existing NASD Rule 2210.The former six categories (advertisements, sales literature, correspondence, institutional sales material, independently prepared reprints, and public appearances) have now been replaced by three: Correspondence, Retail Communications, and Institutional Communications.
Let’s take a look at the two that impact social media:
Correspondence includes any type of written (including electronic) communication that is distributed or made available to 25 or fewer retail investors within any 30 calendar-day period. Like email, these communications do not require pre-approval, but, firms need to capture, retain and make business communications e-discoverable as well as demonstrate that they are supervising communications to meet suitability requirements. An example from social media might include an InMail on LinkedIn, a Message on Facebook, or a Direct Message on Twitter.
Retail communication includes any written (including electronic) communication that is distributed or made available to more than 25 retail investors within any 30 calendar-day period. A “Retail investor” includes any person other than an institutional investor, regardless of whether the person has an account with the firm. Communications that formerly qualified as advertisements and sales literature generally now fall under the definition of “retail communication.” These communications require pre-approval from a principal of the firm, plus all the record keeping and suitability rules apply. However, the rules specifically exempted pre-review any retail communication that:
- is posted on an online interactive electronic forum
- does not make any financial or investment recommendation or otherwise promote a product or service of the firm.
FINRA recognizes that due to the real time nature of social media, pre-review would inhibit interactive communications. Examples from social media include posts such as LinkedIn Updates, Facebook Status Updates, and Tweets on Twitter.
But, what about static portions of social media like profiles and links to content? Tom Pappas, Thomas A. Pappas, Vice President & Director, Advertising Regulation, FINRA, reiterated that the new rule codified existing guidance from 10-06 and 11-39 and that static portions of social media would still require pre-review unless they are exempted as above. In other words, if static content promotes a product or service, it requires pre-approval.
So, will this significantly change processes around social media? Probably not. As I mentioned in my blog, Belbey Blogs: What Are Other Firms Doing?, we have found that firms tend to pilot social media with pre-approval of all initial posts (such as tweets) and keep tight controls in place. Registered persons typically don’t have much latitude. However, once they begin to trust technology to safeguard their firms’ reputation and stay compliant, firms often begin to allow their reps to personalize content to varying degrees.
It just takes time. And some successes to accelerate the process.
For more information, see:
Full text of Communications Rules (32 pages)
FINRA Regulatory Notice 12-29 Communications with the Public (25 pages)
When the social party grows up, what if no one attends?
Posted in Actiance, Collaboration, Compliance, eDiscovery, Employee Behavior, Enterprise 2.0, Financial Services, FINRA, New Internet, Social Networking, Trends on February 6, 2013
Today’s post is a collaboration between Richie Etwaru, Director, UBS and Joanna Belbey, Social Media and Compliance Specialist, Actiance
Our last blog, “Before You Go Social, Check with Uncle Sam” covered the regulatory compliance, corporate governance, and legal requirements organizations must address before deploying social collaboration, or “internal social media.” In short, we suggested firms needed to develop policies and deploy or procure intelligent software to automate the capture, archive, retain, and supervise business communications across the enterprise.
We received material feedback. Readers reminded us that we’ve all been having the “compliance and technology conversation” around social media for some time. We aim to please so asked what’s next; we were told adoption is the biggest barrier to success. How do you make the changes to the corporate DNA to allow collaboration to flourish? In other words, how do you get adoption?
Apparently there is a party happening on grown up social networks but no one is attending.
Solving for Adoption
At the core of the thought leadership, we must look at training, sponsorship and design as three individual agendas solving for adoption. The diagram below shows three audiences for each agenda in a 3X3 matrix. The 3X3 matrix can serve as a maturity model as an organization progresses from top right of the matrix to bottom left.
Training, no one flyer fits all
There is no “one size fits all” training for employees to learn how to be “social” within the enterprise. At the one end of the audience spectrum, are employees who are adept at using social media in their personal lives. These are usually (but not always) entry-level employees. They may freely share personal experiences and thoughts with hundreds (thousands?) of their friends on Facebook or followers on Twitter. This set of employees may need to learn how to be “professionally social” within a corporate environment. There is unlearning, think first, and when in doubt resist, training needed.
In the middle of the audience spectrum training is need to inform the value of social beyond connecting people to people and content, sharing more, and the power of inviting others. For more on value beyond connecting people to people and content see “Solving for building backlash of Enterprise Social Networks” posted by Richie.
At the other end of the audience spectrum are employees who may use social media only occasionally or not at all. These are sometimes (not always) senior management. They may require a bit of handholding, and learning about specific benefits of why they should invest the time to learn something new. They also may be concerned about privacy. There is training needed to trust the platforms, learning the value of connecting to people, and benefiting by searching for and finding content in an entirely new way. This audience will not simply come to the party because they received a flyer, there is personal touch needed.
Sponsorship, they must come from everywhere
Successful deployment of social media (either internally or externally) requires commitment from senior management. However senior managers are unlikely demonstrators of sponsorship for social. Demonstrating sponsorship for social means using it, and many (not all) senior managers lack the time, commitment, and authenticity (don’t take it to heart, being authentic on social is an art, even if you are an inherently authentic person) to truly be social.
Sponsors of social medial must come from all tranches of the organization. The trusted employees, and employees that are opinion leaders can demonstrate sponsorship driving adoption. The trusted must create content, celebrate others, and invite opinion leaders (many times openly). Opinion leaders must share content of others, invite the unlikely senior managers (yes, sometimes openly as well), and advocate for the value of media other than text (such as videos) by using said new media. Finally, senior managers who are seen as unlikely adopters by the masses must be authentic. The unlikely audience should upload photos (authentic photos, not the boring corporate headshots), celebrate the opinion leaders, and share information created by the trusted.
This type of sponsorship and authentic adoption up and down the corporate ladder enables organizations to influence with sponsorship. After all, well attended parties are sponsored.
Design, customize the user experience
Inarguably, social can be separated into the believers, the voyeurs and the nay-sayers. The believers get it, and the current design of social works for them. Empower your believes, celebrate them, and hope that you can challenge them.
The voyeurs are the folks that come to the social platform, look around and leave (people that peek into restaurants or lounges and then keep going). Why do they do this? Many times it is because they “see no value when first logging into a social platform”. For us believes we ask, “really no value?” The fact is voyeurs do not see value when logging in initially, this is because they are not a part of any group, haven’t liked anything, haven’t created any content or commented or shared. Of course they see not value, the initial social experience is empty! Organizations must design social platforms to demonstrate value to voyeurs. We know who said voyeurs are, who they work for and who works for them, their peers constitute their implied social graph. We know what groups their “social graph” are in, what documents and topics their social graphs are interested in, and what questions their social graph have asked and answered. The design of the social platform should suggest a curated environment for the voyeurs on first login based on the activity and preferences of the implied social graph. When a voyeur logs in, if he/she accepts all curated suggestions, he/she will “LEAP” onto the social platform and see immediate value. This is an example of what we mean by enabling adoption with design.
Closing
This conversation can be detailed into a longer discussion, but at the heart of it, adoption is not unsolvable. There is a party happening on the grown up social networks and if no one is coming to the party we have to think like nightclub owners; guide with training, influence with sponsorship and enable a good experience with design.
Content Can’t Take A Vacation (Or Even A Sick Day!) #TLTActiance
Posted in Actiance, Employee Behavior, Enterprise 2.0, Financial Services, Google, Guest Post, New Internet, Social Networking on January 31, 2013
Today we bring you the first of a new series on the Actiance blog: Thursday’s are “Thought Leader Thursdays” (or #TLTActiance). I’ll preface this by saying that the content is entirely that of our thought leaders, who come from all over the world, the industry and from different areas of business.
Our inaugural blog comes from our good friend and colleague in the industry, April Rudin, who you may know from @TheRudinGroup. April writes and blogs extensively, in and around the financial services space. She’s well known for her blogging on @huffingtonpost and you’ll see her at most of the financial services events especially on the East Coast of the USA.
Enjoy the blog! Sarah Carter
One of the most frequent financial advisor/wealth manager miscues in social/digital marketing is the lack of a content calendar or a basic marketing plan. It amazes me how the “planners have no plan” when it comes to new client acquisition or retention. Many people approach it almost impulsively, like opening up a Twitter account, without any clue about how to use it, what their messaging should be, or even an avatar/photo! What’s more, this “play” or experimentation is happening on the most visible amplified platform possible: the internet.
Ugh! How can you avoid embarrassing “Social Media Hall of Shame?” In this blog, I will discuss one aspect which is importance of on-going consistent and constant content. While there are plenty of mistakes and faux pas to make, the easiest to avoid is the “content vacation.” To me, this is the most egregious “offense” and it discredits the firm/advisor to existing/potential clients in the worst way: not following through with a plan. Here are a few examples. An advisor opens a Twitter account, begins following friends, or anyone, and has one solo tweet, something like “I am on Twitter now”. That was last January. The Twitter account has sat vacant since. Isn’t it suggesting that the advisor may behave that way with my assets? Another example is the blog which is posted inconsistently, i.e. January, February, March August, November, (you get the idea!). The “Hall of Shame” blog topics are without any thread linking the blog to the firm or to each other, and, perhaps the blogs were part of a one-time newsletter which has never been repeated again.
Ugh! Ugh! Developing a compelling content calendar can be very helpful in staying on track and on-time. To create an actionable, content calendar, you need to determine: What is the content? Who is the audience? Which platforms will be used? And who is responsible for what? Accountability is the key to creating a system, process for the positioning of your personal and firm’s brand on a regular basis in a way which leads back to you, your firm and new/more AUM.
I asked Kathleen Pritchard, Director and Head of Advisor Development for Legg-Mason about the importance of good, consistent content. Kathleen remarked, “While financial advisors may have limited time and resources, it’s the differentiated content which will attract and engage with your audience.”
Kathleen and I both agree that one way to create a compelling content process to include curating content from guest bloggers such as other trusted advisors is one way to “pepper” your blog with interesting stories tied to the calendar. An example would be to calendar a tax attorney to write a “year-end” blog. Inviting other third-party experts will also assist in your outreach as the contributor is likely to send your blog out within their own network as well. Repurposing the same content is another way to help and using evergreen content which is not time-sensitive can be useful in your calendar.
The brevity of this blog and the complexity of this important messaging are at odds. I have so much more to say but limited to 500 characters. Contact me.
April may be contacted via email at april@therudingroup.com or on Twitter @TheRudinGroup
Belbey Blogs: Before you go social, check with Uncle Sam
Posted in Actiance, Collaboration, Compliance, eDiscovery, Electronically Stored Information (ESI), Employee Behavior, Enterprise 2.0, Enterprise IM, Facebook, Financial Services, FINRA, Guest Post, Legal, Social Networking, Unified Communications, Web 2.0 on January 30, 2013
Today’s post is a collaboration between Richie Etwaru, Director, UBS and Joanna Belbey, Social Media and Compliance Specialist, Actiance
It’s difficult to debate the value of installing enterprise social networks.
Richie Etwaru, a futurist and avid speaker, covered the current state, business value, and future thinking needed around the construct of what he phrases the #ENTSOCNET (an internal enterprise social network). Mr. Etwaru titled the piece Solving for building backlash of Enterprise Social Networks and covers the 1st, 2nd and 3rd generation of the #ENTSOCNET. Installing an internal social network, driving, adoption and extracting business value as Mr. Etwaru describes, is complicated and difficult work. Leaders must ensure that said complicated and difficult work is being done under the auspices of regulatory guidelines.
There are regulatory compliance, corporate governance, and legal requirements organizations must address before deploying social. There however, is an impedance mismatch and some amount of misinterpretation between what the regulators consider enterprise social media, and what leaders in the enterprise consider to be enterprise social media. The spirit of the regulations suggest that whether an enterprise in installing an internal social network (what Mr. Etwaru describes as the #ENTSOCNET) for its employees only, or leveraging external social networks such as Facebook, LinkedIn or Twitter; all communications, messages, inboxes, comments, endorsements, DMs, tweets retweets etc. are governed under the regulations.
What Regulators want
More than 2 years ago, regulators of the securities industries began to issue guidance on how to use social media. The Financial Industry Regulatory Authority (FINRA), The Securities and Exchange Commission (SEC), Investment Industry Regulatory Organization of Canada (IIROC), National Association of Insurance Commissioners (NAIC) and others view social media, whether it’s external or internal, as just another form of business communications, such as email or instant messages. They remind us that it’s the content that is determinative, not the platform. Regulators also expect that firms demonstrate that they are supervising, or reviewing, a pre-defined portion of these communications. Other more general legislation may also apply such as Sarbanes-Oxley (SOX) Gramm-Leach-Bliley Act, and the data breach notification laws (PCI, DSS).
What this all means
In short, whether internal or external, firms need to ensure that all business communications (or “business as such”) are captured, archived, supervised and made easily e-discoverable. There is nothing new here as this has been an evolution. First paper, then email, instant messages, now both internal and external social media, firms continue to be challenged to capture, retain and review a portion of all business records in whatever form they appear. As a first step, firms may use their existing email and instant message retention policies as a framework to develop policies for internal and external social media. Governing said policies is a separate and pronounced challenge.
Governance is key
Firms are increasingly committed to comprehensive corporate governance to avoid scandal and to comply with regulations. The development of sound policies and procedures before deployment is key, given the vast amount of data stored in most collaboration environments and the free ranging conversations among employees, contractors and even clients that can ensue, policies must be defined.
Specifically policies should address: records management (retention, litigation readiness, privacy), information management (making sure that records are tamper proof, and easily accessible), data deposition (disposal of data) and conflict management. Where possible, firms should automate policies with technology to protect their intellectual property, prevent the creation and distribution of inappropriate content and provide an audit trail of all activity to ensure accountability.
It’s a serious legal matter
When learning of pending litigation, firms must be able to preserve all records (“legal hold” or “ligation holds”) that may relate to legal action against the company, including records of social activity. According to the Federal Rules of Civil Procedures (FRCP), firms must meet discovery requests for paper as well as electronic documents (spreadsheets, slide decks), emails, posts, and conversations across social media in a timely fashion. Therefore, firms need plans and the means to retain and produce such data upon request. Email was new and difficult, social is not yet understood, complex and mindboggling.
Social, not my grandma’s email
Social media, due to its nature, adds complexity to these requirements as interactions occur over time. For example, a blog starts with an initial post, then readers may add comments, or change their minds and revise and delete their comments and the original author may respond. These interactions could go on for months in some cases. Firms should have the ability to produce all of these threads of posts, comments and replies “in context” to give meaning to the conversations. By providing context, firms may reduce litigation costs by reducing the number of hours required by attorneys to sort through records to determine the sequence of events and the true essence of the conversations. Preserving context requires intelligent software solutions.
What now
Enterprise-wide “social business” tools were designed to facilitate collaboration, not necessarily to meet the legal and compliance requirements of regulated firms or public corporations. They offer basic functionality to capture and archive communications, but not the reporting, contextual view of information, nor granular policy setting that may be desired. Firms are therefore advised that before deploying enterprise wide collaboration tools, they look to third party vendors to ensure their compliance requirements are met.
Collaboration, no pun intended
I reached out to Mr. Etwaru (whom I met a few years ago at a conference in NYC) and shared this perspective. His response is below.
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Hi Joanna,
Your thoughts are spot on. From the regulators (who are doing a great job) point of view social, email, chat, etc. all carry similar risk and hence are metaphorically bucketed from a guidance standpoint. In the enterprise however, the risk with social is multiples higher for a multitude of reasons. One reason is employees learned of social in their personal lives where regulations are by and large absent. Hence, when using social in the enterprise (or in a commercial manner) employees (fallible as we are) tend to assume the same “free range” comes with social. The policy, governance and education you suggested is paramount, I could not agree more.
That being said …
However daunting all of this may be, the biggest risk is not using internal social media to break down silos and to unleash the intellectual power of the enterprise while driving innovation.
BTW, love your diagram, I can help you make it pretty
Hope this helps,
-R
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Diagram above rendered by Mr. Etwaru,
-Joanna
Belbey Blogs: Visiting the Taj Mahal #TravelTuesday
Posted in Travel, TravelTuesday, Uncategorized on January 29, 2013
No matter what anyone tells you, you are never prepared for the Taj Mahal. We’ve all seen pictures of it of course. And we’ve heard the romantic story of how Mughal emperor Shah Jahan was so grief-stricken at the death of his third wife, he spent 22 years building a monument to her memory. But, what’s it like to visit?
First of all, it’s crowded. Lots of hustle-bustle getting tickets and walking through various lines and checkpoints, then suddenly, you are amidst a sea of people all crowded into a dark hallway.
Look up and there it is!
Beautiful.
Then, everyone takes turns taking the classic “Couple Standing in Front of the Taj Mahal” shot.
Then a walk along a reflecting pond with stunning details.
Then taking off our shoes. Then lines.
And more lines.
And more lines.
White marble everywhere. It’s breathtaking of course, with stunning architectural details.
We’ve all seen those too.
But the part that no one ever tells you, is that everyone is so happy!
And playful.
The Taj Mahal is more than a monument, it’s a living celebration.
In Shah Jahan’s words:
Should guilty seek asylum here,
Like one pardoned, he becomes free from sin.
Should a sinner make his way to this mansion,
All his past sins are to be washed away.
The sight of this mansion creates sorrowing sighs;
And the sun and the moon shed tears from their eyes.
In this world this edifice has been made;
To display thereby the creator’s glory.
Belbey Blogs: New Guidance on Using Social Media at Retail Banks
Posted in Actiance, Collaboration, Compliance, eDiscovery, Electronically Stored Information (ESI), Employee Behavior, Enterprise 2.0, Enterprise IM, FFIEC, Financial Services, FINRA, Legal, Malware, Privacy, Retail banking on January 25, 2013
This week, the Federal Financial Institutions Examination Council (FFIEC) released “Social Media: Consumer Compliance Risk Management Guidance. The FFIEC is asking for comments within sixty days. You can download the 31-page document here.
Its release has created quite a stir within the banking industry. A comprehensive article appeared on TheFinancialBrand.com, “Regulatory Shocker on Social Media in Banking Coming Soon” that summarizes the guidance quite nicely.
But . . . what’s so shocking?
We’ve been having the same conversations in the securities industry for three years. And in those three years, firms have learned that there are three major areas of risk that need to be mitigated before deploying social media:
- Security: your IT department needs to prevent your firm’s proprietary and client information from being leaked out either inadvertently or maliciously from the enterprise. They also need to ramp up malware protection. That’s because social media users are susceptible to incoming threats as they view themselves as part of a tribe and tend to click on any link sent by a “friend.”
- Compliance and Governance: your legal and compliance departments already know that there are thousands of rules and regulations that govern the communications and advertising of publicly held corporations, firms in general, and bank specifically. Take the securities industry as an example – the banking regulators aren’t issuing new rules and regulations around social media. Social media is viewed as just another form of written communications. Your compliance department is therefore challenged to interpret existing rules as they apply to social media and to develop and enforce firm policies.
- Enablement: your executive team is concerned about productivity and the bottom line. Now that every employee can be the face of the business, you either have a powerful marketing tool or your worst nightmare. Employees will need to be trained on how to use social media effectively to meet the firm’s goals, such as nurturing existing clients, attracting new business, recruiting, and brand awareness.
However, during the last three years, we’ve learned that all these risks can be mitigated by strong corporate polices, backed up with technology and training.
So far, so good. Nothing new here. Or is there? In addition to what we’ve already seen from other regulators, the FFIEC specifically also calls for:
- Creation of policies to address negative feedback or customer complaints, even if a financial firm chooses not to actively engage in social media.
- Monitoring to protect the firm’s brand identity
- Due diligence and oversight for third-party vendors that firms may hire in connection with social media
And the one that I find most interesting:
- Processes and reporting to demonstrate how social media “contributes to the strategic goals of the institution.”
In other words, the FFIEC recommends that firms measure the ROI of social media.
It will be interesting to see the reaction that FFIEC gets from the industry. I just hope that the banking industry can use some of the key learnings from the securities industry to streamline the processes to reap the benefits of “getting social.”
For more details on how to deploy social media within retail banking, you can also check out Belbey Blogs: Upcoming Guidance for the Use of Social Media for Retail Banking from FFIEC.
