Tag Archives: compliance

O Canada, O IIROC


By nleong,   December 6, 2012

I just got back from a quick trip to the Great White North.  NHL teams are still locked out, which might explain the forlorn look on folks I met or walked by.  Luckily, the absence of hockey didn’t put a damper on IIROC’s Compliance and Legal Section (CLS) annual conference.  Sessions were lively and informative, especially the social media one, and people seemed generally optimistic that the NHL season could still be salvaged.  It was optimism all around.

IIROC lives, hockey or no hockey

IIROC lives . . . hockey or no hockey

Much like its FINRA brethren, IIROC has its own social media-specific guidelines in the form of Notice 11-0349.  I swear, looking at FINRA’s 10-06/11-39 and IIROC’s 11-0349 side-by-side, you’d think you were seeing double.  Even the session topics looked similar to what you’d see at the FINRA events.  Just like in the States, the social media session was packed.

At the IIROC one, the panel consisted of an attorney, a compliance officer, and a marketing executive – the exact same key stakeholders you see involved in social media enablement efforts south of the border.  In fact, as a whole, I got the impression Canada is not so far behind the US in terms of adoption of social in the financial services industry.

I heard repeatedly that Canadian firms were slowly opening up access to social and getting the ball rollin’ on pilot programs.  So, the trend seems to be that, if you’re a financial institution, you should at least be considering social or else you’re gonna be left behind.  That was the consensus of nearly everyone I spoke with.

2013 is just around the corner, and I’m expecting big things out of our friends up north.  They’ve had a year to take notes from their US counterparts, guidelines are in place, social media policies are being drawn up, and there’s a still chance for an NHL season.

We just need Rush to belt out “O Canada” and all will be good.

The Risk of Doing Nothing


By Victor Gaxiola,   November 6, 2012

Today’s post comes from Victor Gaxiola, Social Media Subject Matter Expert at Actiance.

Last week I had the privilege to present on Social Media in Ethics & Compliance as the invitation from the UC Berkeley Center for Executive Education.   Thought leaders from banking, health care, energy and other regulated industries were present to discuss the challenges facing their professions with the growth of social media and the blurring lines between personal and professional content and use.   Although each group is regulated differently, the concerns are the same.  How do we control what others say, and is the associated risk of social media adoption worth the potential rewards?    As a group we concluded that the answers are not universal or easy to attain as each organization approaches social media according to their own industry and policy.   However, what we could agree on was that it can no longer be ignored that social media is pervasive in the workplace and that it needs to be addressed- even if it means that participation is not an option.

Not having a social media policy is a policy- and in general not very good one.  So my recommendation to those that are keeping it at bay is to at the very least spell out for your employees WHY you have chosen not to participate, and outline the consequences for breach.  It reminds me of the Nancy Reagan “Just Say No” anti-drug campaign of the 1980s.  Although effective in building awareness- it wasn’t enough, because you’ve got to give people something to say YES too.

At Actiance we recognize that Financial Services firms and other regulated industries are completely justified in not wanting to use social media.

So with all these risks, and costs, it is easy to understand why so many firms’ social policy is still simply, “NO.” However, I would argue that the risk of doing nothing NOW is worse for a host of reasons.For one, by being overly cautious, your firm will blend into the vast majority of other firms not using social media and lose its competitive advantage.  The window for opportunity in social is not going to be open for too long, and early adopters will be rewarded by recruiting the next generation of advisors and investors.  Although there is always the risk of making a misstep, early adopters to any new technology stand out from the competition and tend to be forgiven for their mistakes more easily. Another factor to consider is that going forward by not participating, you risk having your brand being seen as non-innovator which could negatively affect the perception of customers, employees and suppliers. You will also miss out on opportunities to build awareness for your brand and to improve efficiency of learning, teaching and research, left with using costly traditional research methods.

However, the most serious risk of not using social media is that your firm will be unable to interact with customers in the manner they prefer.  Let me say that again… THE MANNER THEY PREFER!   This is not about you, it’s about them.

Financial services firms tend to think that as their customers are older, they don’t use social media. However, this is not borne out by facts. Although Generation Y and X are the most enthusiastic users (with 87% and 77% respectively), more than 47% of Boomers use social media in some form*.  That should be incentive enough. However, predictions for the future are even more interesting.

Today, in the U.S., Generation Y accounts for $2.4 trillion worth of personal income and by 2025 Generation  Y will account for 46% of personal income**. In other words, by not using social media, your firm risks not using the preferred method of communication for people who control nearly half of all the personal wealth.  I think leaving half of all the wealth in the United States on the table seems like a very big risk indeed.    Is it one you can afford to take?

* USA, Source: Forrester Research, June 2011
**Javelin Research http://www.stltoday.com/business/local/article_719f49d8-15e6-5c5d94b7992ab12d9f97.html?print=1

The Demise of the FSA and the Future of Financial Promotions


By actiance,   September 14, 2012

Although the Financial Services Bill is still going through the House of Lords, in less than nine months time the demise of the FSA will be complete. Its replacements, the PRA (Prudential Regulatory Authority) and the FCA (Financial Conduct Authority) have issued guidelines on their approach, but their current lack of detail on financial promotions has left many firms confused about the future.

The biggest initial change I think we are going to see is not new guidelines, but a stricter enforcement of the current ones with heavier fines for those that stretch the mark. One of the contentious issues around this is the proposed public “early warning” notices of firms that do not comply and the cutting of the right to reply from 28 to just 14 days.

The FCA guidelines state: The government intends that the FCA will have new powers in product intervention; to direct firms to withdraw or amend mis-leading financial promotions with immediate effect; and to publish the fact that a warning notice in relation to a disciplinary matter has been issued.

Besides the problem of drawing adverse attention to a potentially innocent firm, there are other issues to consider. Retrieving the evidence of a print or email-based marketing campaign to argue your case is relatively easy, but trying to collate proof around a social media campaign that’s taken place over several different platforms is time-consuming without an adequate contextual archive.

14 days is a long time if warning notices are issued and waiting that long to demonstrate publicly that it was within the regulation is not really an option for a firm looking at damage limitation and protecting its reputation. A successful, or indeed notorious, social media campaign that’s been running for just a week can produce a vast amount of content that will need to be reviewed. But working out who said what, who saw what, whether they were public messages or private DMs takes time if you’re doing it manually or using disparate databases. Not to mention the additional headache if the campaign actually ended months before.

In addition, the PRA outlines that it may even intervene in a financial institution’s business, citing the Japanese Financial Services Agency that in 2009 banned the retail division of a large financial institution from advertising and running sales campaigns for one month after it failed to maintain required standards to control money laundering.

We’ll have to wait until October when the House of Lords meets again to discuss the Financial Services Bill to see if the early warning notices will remain, but either way there are several things firms can do now in preparation for the final transition.

Review your risk within the current FSA guidelines, amended your policies and procedures if you find them lacking and starting thinking about using technology not just to enforce them, but to help you understand the situation and react quickly if something does go wrong. Even better, put a strategy in place that allows for real-time monitoring, compliant logging and archiving and content control that means that even if audited, you know you are safe when using Social Media as part of a marketing portfolio. The cost of implementing such an approach will always be significantly lower than the potential penalties for not doing so.

Belbey Blogs: Social: Personal Meets Professional – your top questions answered!


By Joanna Belbey,   August 2, 2012

Today’s post comes from Joanna Belbey, Social Media and Compliance Specialist at Actiance.

Microsoft recently announced integration within Outlook with LinkedIn, Facebook, and Live Messenger. What does that mean exactly?

When you send an email, you will see a detailed history of your interaction with your contacts, plus  their photos and status updates on Facebook and LinkedIn. In other words, rather than the two-step process of looking at someone’s profile on LinkedIn or reading their Tweets, and then sending an email or a meeting notice, everything’s right within Outlook.

In short, Microsoft has just made it easier to understand and relate to our clients and colleagues. And for them to get to know us better. They’ve accelerated the movement of the integration between the personal and professional.

Did you just say, “cool!”? or did you cringe?

As a Social Media and Compliance Specialist at Actiance, I speak at industry events and meet face to face with professionals within the financial services industry. My mission is to help enable the effective use of social media within the enterprise while complying with the rules and regulations. Every day, I see firms moving away from their original stance of “No!” to social media to beginning to puzzle out the “How?”. They are collaborating across departments like Marketing, Legal, Compliance, Investor Relations, Human Resources, IT and Security to develop social media policies. They are working through the compliance issues and selecting vendors like Actiance to help them enable their financial advisors to use social media while protecting their firm’s brand and staying compliant.

But what do the end users, the Financial Advisors, think about what’s coming?

I recently spoke in Boston and New York at “Social Media Marketing: Don’t Forget the Sex” conducted by WealthManagement.com and Actiance. Although the events had a provocative title, the sessions took a serious look at the demographics of adoption of social media. According to a study by WealthManagement.com, Financial Advisors under 35 are more likely to use social media for business purposes than those 55 or older (68% vs. 45%). No surprise there. But, what was surprising is that with a bit of prodding and some training on Best Practices, advisors over 55 tend to get better engagement. Once they learn the tools, they recognize that social media is just another way to interact with prospects and clients.

In both cities, I found financial advisers who were nervous about using social media. They asked me the same questions:

Q: “How do I separate business and personal?”

A: Unless your firm has a special arrangement with LinkedIn, you can only have one account. On Twitter, you may set up separate accounts (e.g., @Belbey and @Belbey_Actiance) and even make them private. And for now, you can only have one identity on Facebook, so depending on your firm’s polices, from your personal profile you create a business page and direct your clients there. Or, if you don’t already have a Facebook account, you can set up just a professional page. However, these workarounds miss the point. Instead of thinking about how to shield your personal life from your clients and colleagues, think about how to let your personality shine through. Remember, with Microsoft’s announcement, true integration between personal and professional is coming…. If you have a passion for Bruce Springsteen, movies, golf, sailing, your alma mater or just couch surfing, let your connections know it.

Q: How much of my personal life do I need to reveal?

A: If you are using social media primarily for business, Jason Seiden (@Seiden), Co-Founder and CEO of Ajax Social Media suggests making 20% of your updates personal, in order to be authentic. After all, we buy from people with similar interests and who we like, right?

Q: “How can I protect my clients from being poached by other financial advisors?”

A: On LinkedIn, you can make your connections private by changing the settings, on Facebook you can change the privacy settings and control who can see what, and you can even make Twitter private. But, again, this question misses the point. Rather than “defense,” think “offense.” If you are helpful and engage with your prospects and clients on social media, you will strengthen the relationship, not lose it to some stranger.

Q “How much time will this take?”

A. If your firm provides a library of pre-approved content and technology to schedule updates, posting content and interacting on social media won’t take much time at all. Perhaps an hour once a week to schedule your updates, and then 30 minutes a day to interact with your connections / followers / friends.

Q. “How do I start?” And “What do I say?”  and the biggest unspoken question, “How do I avoid looking foolish?

A. Good questions. Before you begin to use social media, be sure to read your firm’s social media policy for direction. Hopefully, they will provide training on Best Practices and how to comply with the communications regulations. And it’s always a good idea to listen for awhile to begin to understand how it works before you jump in. And of course, use common sense. This is a public forum. Bottom line: approach social media through the lens of being helpful to your connections. Think about your clients. You might specialize in working with entrepreneurs, or small businesses, women, or perhaps ultra-high net worth individuals. Share content that they might find useful or interesting. To help you, many firms create a library of pre-approved content that you can tap.

The true integration of business and professional through Microsoft and Social Media won’t be implemented at your firm overnight. But, once it does, will you be ready?

FINRA Field Trip


By nleong,   June 28, 2012

After last month’s annual FINRA conference wrapped up, the Actiance team decided to stick around for an extra day to stop by FINRA headquarters and meet up with some key folks in the Advertising Regulation division to talk about social media and technology.  Judging by how many social media-related sessions there were at the conference (that would be 3), social is definitely a hot topic these days for FINRA, the SEC, and their regulated entities.

This is a marked change from the last annual conference when only Regulatory Notice 10-06 was in play.  Now, there’s also Regulatory Notice 11-39, a FINRA social media sanction (Jenny Ta), an SEC risk alert on social media, and an SEC enforcement action (Anthony Fields) to gnaw on.  What all this points to is continued interest in social media by the regulatory bodies and the firms they oversee.  As technology chugs along to keep pace with the social media train, so too is the need for regulators to “stay in touch” with what’s going on out there, hence, our visit to Rockville, MD.

And just as FINRA looks at social media to see how the latter is used by member firms for marketing and advertising, the regulator is also curious as to how technology is aiding firms in their marketing initiatives while also remaining compliant with FINRA guidelines.  In many ways, it’s a symbiotic relationship:  regulatory guidelines create a business driver for firms like Actiance, while technology helps member firms stay compliant.

Actiance maintains ongoing dialogues with all the key regulatory bodies, which paves the way for the ideal mix of features and training that helps our customers achieve their marketing and compliance objectives.  Because we understand what the regulators are looking for, their mindset, and the direction they’re headed, we’re able to design our platform and training programs accordingly.  Case in point:  Actiance was instrumental in persuading the SEC to incorporate social media into Rules 17a-3 and 17a-4.  Because we cut our teeth in the IM world, we have the expertise and credibility to regularly engage with regulators and educate them on the technology trends that they need to be wary of when thinking about future guidelines.

Certainly, in an industry known for its strict guidelines and regular audits, a technology partner that understands these rules is vital indeed for ensuring that all FINRA-regulated firms can confidently deploy these technology solutions to remain compliant.  Actiance in particular has ex-FINRA members, attorneys, and financial industry pros on its staff to eliminate any confusion or doubts customers might have on what is necessary to ensure compliance in a world of dynamic communication channels.

We confidently believe that social media won’t go away any time soon, so we envision the symbiotic relationship continuing, evolving, and flourishing.

Belbey Blogs: Let‘s Change the Conversation


By Joanna Belbey,   February 8, 2012

At a meeting last week with a prospective client, while we were diving into freshly baked cookies (yes, that’s right, warm cookies, I love meetings in the Midwest), a compliance professional turned to me and asked me a question about “PAC files”.  Really?

At that moment, I realized that it’s time to change the conversation.

For more than 2 years, we have been discussing how to use social media while complying with the financial services rules and regulations. After all, Financial Industry Regulatory Authority (FINRA) issued its first Regulatory Notice 10-06 in January of 2010, followed by the Financial Services Authority (FSA), Financial Promotions Using Social Media, and then came Cir/ISD/1/2011 from the Securities and Exchange Board of India (SEBI), then more guidance from FINRA with Regulatory Notice 11-39 followed by Investment Industry Regulatory Organization of Canada (IIROC) issuing  11-0349, and the Securities Exchange Commission (SEC) alerts early this year, that included Investor Adviser Use of Social Media.  In addition, the National Association of Insurance Commissioners is drafting The Use of Social Media in Insurance. We have even seen the Massachusetts Securities Division issue a letter to Registered Investment Advisers on the use of social media.

Fundamentally, we are reminded by all these regulators that social media is just another form of written communications, and needs to be treated as such. Existing rules around recordkeeping, suitability, advertising, and supervision are media-neutral and all apply. Content, not the device is determinative. And the regulators are only interested in business communications. With the release of each new set of guidance, there are lively conversations about how to interpret and apply some of the rules to specific features across the social networking sites, however, at this point, the message is clear, spirit of the guidance is to protect the investor.

As none of the native social networking sites have ability to support these compliance requirements, project managers, IT and Security have been having their own discussions. Third party vendors have been identified, requirements outlined, demo after demo watched, pilots launched, RFPs written and evaluated, matrixes comparing vendors developed and analyzed, budgets submitted, resources assigned and contacts negotiated. In some cases, upward of 30 people from within the enterprise have been involved in all these conversations. No wonder the compliance professional had heard about “PAC files”.

In the meantime, the lines of business, marketing departments, investor relations, human resources, research, customer service, and savvy financial advisors are chomping at the bit to start using social media to nurture existing relationships, attract new clients, build brand awareness, share information, do recruiting and conduct research. Maybe they have heard the statistics: more than 47% of Boomers use social media in some form (Forrester Research, June 2011) and the heaviest users of social media, Gen Y (ages 18-30) hold more than $2.4 trillion in personal income and by 2025 will control more than 46% of the personal wealth in the United State (Javelin Research). They want to speak to the language of their clients and prospects. Or maybe, they have heard the stories about how financial advisors are beginning to generate business. Like the advisor at a large broker-dealer who captured a new $2 million dollar account after noticing that a LinkedIn connection had retired. Or the advisor who attracted a $1 million prospect after only 96 tweets and with only 51 followers.

So now that you ensured that your firm will be in compliance with the rules and regulations and you have decided which technology solution to use, let’s change the conversation. Let’s talk about training, integrated marketing, content strategy and measurement. And how you will begin to support your Financial Advisers’ use of social media to build their business.

Let’s not forget social media in discovery strategies


By nleong,   January 25, 2012

Up until very recently, social media eDiscovery was often overlooked (or just plain ignored) by law firms and organizations alike.  That’s changing though.  With an increase in case law emerging on social media issues, it was inevitable that the legal community would start to incorporate social media communications into their discovery strategies.

The recent  sanction of an attorney in Virginia underscored the importance courts now place on proper discovery of social media content.  At the end of the day, social media is just another form of electronic communication, much along the lines of email and instant messaging.  It’s the content that matters, not the communication channel.  In fact, whether it’s for corporate governance, regulatory, or eDiscovery purposes, the identification and collection of social media content is absolutely critical.

I’m excited to present at LegalTech New York this year.  Social is on everyone’s minds.  Case law is growing on the topic.  And technology is keeping pace.  In addition to speaking in New York, I’ll also be hosting a regular webinar on social media eDiscovery.  We’ll be hosting our first Social Media eDiscovery webinar on February 8th at 11am PT, so we encourage you to sign up and find out what your organization should be doing with respect to social and what tools are available to facilitate the discovery process.

Social’s not going anywhere, so it’s best to be prepared if the courts get involved….

Belbey Blogs: Rick Ketchum, Chairman of FINRA, Highlights FINRA Exam Priorities for 2012


By Joanna Belbey,   January 19, 2012

At the  SIFMA Compliance and Legal Monthly Luncheon held at the Harvard Club in New York on January 17, Richard Ketchum, Chairman and Chief Executive Officer of FINRA outlined exam priorities for 2012.

Mr. Ketchum acknowledged that these difficult markets, the search for yield, and the changing regulatory landscape due to the implementation of Dodd Frank can place “tremendous pressures” on firms, clients, and Compliance departments.  But, at the end of the day, the mission of FINRA is to protect investors.  He stated that he hoped that his remarks before the group of mostly attorneys and other compliance professionals would “ get your blood running, if not running cold,” as he encouraged everyone to “step up” to meet compliance challenges and respond  in an honest way to the lessons we’ve learned over the last few years.

In the next few weeks, FINRA will release its Annual Exam Priority Letter.  The following are a few advance highlights:

Complex Products – Heightened supervision is required with enhanced compliance procedures to ensure that reps, supervisors, and retail investors understand complex products.  See Regulatory Notice 12-03 for details.

Supervision – Firms must demonstrate responsibility for all business lines they engage in, in spite of increased difficulty, complexity, and customer frustrations with return on investments.  Firms must demonstrate proper supervision.

Suitability – Changes to FINRA “Know your customer” Suitability are rules going into effect July 9th. Examiners will review the steps firms are taking to prepare for changes and implementation once rules are in effect.  See Regulatory Notice 11-25 for details.

Data Security – In light of sophisticated attacks against firms, FINRA is looking for equally significant defenses, including attention to emerging markets.

Social Media – FINRA has issued two notices, Regulatory Notice 10-06 Guidance on Blogs and Social Networking Web Sites and Regulatory Notice 11-39 Guidance on Social Networking Websites and Business Communications.  Examiners will focus on the supervision and recordkeeping of all business communications, regardless of device; the pre-approval of static content; supervision of interactive content on a risk basis; and the adoption and entanglement of third-party content resulting in a firm being responsible for that content.  Furthermore, FINRA examiners will check whether a registered principal of the firm has reviewed social media sites before they are launched; if there are links to third-party sites with false or misleading content; that firms have established policies to ensure the accuracy of third-party data feeds; and when firms allow the use of personal devices, they must demonstrate the ability to supervise and keep records of those business communications.

Mr. Ketchum noted that FINRA welcomes continued feedback from the industry on any and all issues and is looking forward to a three-way conversation  - specifically about social media and FINRA, the industry, and the SEC — that sets so much of the record-keeping requirements in the industry.

So, watch for FINRA’s Annual Exam Priority Letter soon and continue to take a careful look at how your firm is complying with FINRA rules, including following FINRA’s guidance on social media.  And consider writing a letter to Mr. Ketchum and FINRA to share your key learnings as you begin to deploy social media within your enterprise.

Actiance and IBM: Enabling Social Business


By nleong,   January 17, 2012

Most of the Actiance team is off at Lotusphere this week – and while I expect a few of them will be sneaking away from the show floor early to visit the “Magic Kingdom,” I’ve been left to captain the ‘blogging ship’ as it were.  So, as a nod to the Actiance team at Lotusphere and to longtime Actiance partner, IBM, I wanted to write about some great news for IBM Connections users and Actiance customers.

At the event, Actiance is showcasing the result of a partnership with IBM – Vantage for IBM Connections.

When most people think about what the term “social business” means, they typically don’t think regulatory compliance and eDiscovery.  But, businesses moving into social face increased regulatory compliance requirements.  Add in the requirement that social content needs to be discoverable and suddenly the internal IT team is in over its head trying to make social business work.

That’s why Actiance has partnered with IBM to make it easier for IBM customers to adopt social collaboration tools.  IBM customers can now access Vantage Compliance support for IBM Connections and IBM Sametime through the IBM Passport Advantage (PPA).

Vantage for IBM Connections provides a centralized governance, management, and security policy framework to ensure compliant, discoverable social content (it also allows granular policies to be defined between end users, groups of employees, and even non-employees).

I know the team is excited to showcase our new Vantage for IBM Connections compliance module (available exclusively through IBM) at Lotusphere this year.  We’ve already seen a tremendous amount of interest in the module from customers looking to better enforce corporate use policies and enable collaboration.

If you’re attending Lotusphere this year, please stop by Actiance booth #521 – we’d love to hear about what your organization is doing to enable social business.  If you have questions about Vantage for IBM Connections – let us know in the comments section below – we always enjoy talking social business!

Belbey Blogs: FINRA is NOT backing off social media


By Joanna Belbey,   January 6, 2012

In recent weeks, there has been some confusion about FINRA’s stance on social media.  Between one source and another, it seems as if there’s a general feeling that FINRA is “backing off” from social media.  We don’t agree.  We’re going to attempt to clarify FINRA’s position, but first, some context.

Since the consolidation of NASD and the regulatory function of NYSE in 2007, the newly established entity, FINRA, has worked towards creating a new, consolidated FINRA Rulebook.  The goal is to harmonize and streamline existing rules (from NYSE and NASD), adapt to the changes in the securities industry, and create a set of rules that are flexible enough to be used across different types of firms regulated by FINRA.

As FINRA has clearly stated that social media is just another form of electronic communications and should be treated as such, firms are closely watching FINRA’s progress on the consolidation of rules that impact social media, such as supervision, bookkeeping, and communications.

In July 2011, FINRA filed proposed changes to Communications with the Public rules with the Securities Exchange Commission.  Since then, there have been two rounds of comments from the industry with FINRA submitting the final proposal for changes on December 22, 2011, to the SEC.  The SEC is accepting comments from the industry until January 18, 2012, and will comment on the proposed rule sometime after that.

The issue that has everyone talking within social media circles begins on page 10 of the December 22nd letter.  The current NASD Rule 2210 specifies six types of communications, with different regulatory requirements for each.  One category, “Public Appearance,” used for “participation in a seminar, forum (including an electronic forum), radio or television interview” was where FINRA originally classified interactive posts on social media.  That meant that firms were responsible for supervising such activities to ensure compliance with content standards and maintain appropriate records but were not required to file these posts with the FINRA Advertising Department.  (A sidenote for those of you unfamiliar with the regulatory process:  depending on how they are categorized, certain advertising and sales literature materials need to be both pre-approved by a registered principal of a firm and then sent to FINRA for review and approval.)

Under the new rule, however, FINRA Rule 2210 would be streamlined to have only three categories of communications and “Public appearance” would no longer be a separate category under communications.  Instead, FINRA has proposed categorizing social media as “Retail Communications,” which has a different set of regulatory requirements.  When the industry expressed concern that this would make using social media overly complicated for firms, FINRA specifically excluded posts on online interactive electronic forums from filing requirements.

However, it’s important to note that although social media may not be subject to filing requirements with the proposed rule, firms still need to ensure compliance with content standards and bookkeeping requirements like any other written communications.  That means that social media communications need to be captured, supervised, archived, and made available upon request.  Filing is not archiving after all, and a number of folks appear to have been confusing the two terms.

Backing off social media?  We don’t think so, especially when the SEC issues two alerts and charges a firm with the fraudulent use on LinkedIn in one day.  In fact, we think that the regulators will pay close attention to the use of social media in the coming year to demonstrate their commitment to protecting investors.

Are you ready?  We’re certainly standing by.  In fact, we’re planning on putting on a webinar once FINRA 2210 is finalized, so watch this space for details.  And feel free to contact us if you’d like to chat about your specific social media concerns in the meantime.