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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
Division of Investment Management of the Securities and Exchange Commission Issues Guidance Update on Social Media Filings by Investment Companies
IM Guidance Update March 2013
FINRA Rule 2210
Regulatory Notice 12-29 Communications with the Public
Regulatory Notice 10-06, Social Media Web Sites: Guidance on Blogs and Social Networking Web Sites (January 2010)
Guide to the Web for Registered Representatives
FINRA: RCA – March 1999 – Ask the Analust – Electronic Communications
As human beings, our behavior hasn’t changed for centuries. We naturally socialize. Socializing our buying decisions is something that we have done for centuries. Social media simply allows us to connect with those wider social groups—geographically—making our social groups more potent as our social interactions become public through social media.
As social media continues to evolve, so too does its usage and the regulations surrounding those professions adhering to compliance requirements. Starting in 2010, the Financial Industry Regulatory Authority (FINRA) issued regulatory notices to provide guidance regarding the use of social media in the financial services profession, specifically Notice 10-06 and then in 2011, Notice 11-39.
Why haven’t more financial services firms embraced social media as part of their sales and marketing programs?
Some of the key reasons are regulatory.
FINRA, the Securities and Exchange Commission (SEC), and several other regulatory bodies outside the U.S., each impose strict guidelines and rules on the use of all electronic communications, including social media. This demands careful oversight of online communications and activities to ensure that financial advisors aren’t using social media channels inappropriately or without retaining records of all communications.
A sampling of Social Media-Related Notices and Rules
- FINRA Regulatory Notice 10-06: Summary: Static content on social media sites and blogs are considered advertisements and need to be pre-approved. However, interactive content, like chat rooms, is considered non-static and does not require pre-approval by a registered principal prior to use.
- FINRA Regulatory Notice 11-39: Summary: To answer some of the questions raised by Notice 10-06, this notice clarifies that it’s the content of the communication rather than the channel that is being reviewed. Firms are also subject to the “adoption” and “entanglement” theories regarding third-party posts, and that business communication through personal devices must be supervised and recorded.
- NASD Rule 3010: Summary: Members must establish, maintain, and enforce written procedures for communications of registered representatives
- IRS Circular 230: Summary: Tax professionals could be subject to penalties regarding written advice, including their use of social media such as blogs, and Facebook, LinkedIn, and Twitter comments.
- New FINRA Rule 2210 (effective February 2013): describes various communications categories (institutional, retails, correspondence), and approval, review and record keeping requirements for each
- SEC Rules 17a-3 and 17a-4: require written, enforceable retention policies, searchable index, viewable and readily retrievable, offsite storage, and storage of data on WORM (write once, read many) optical media
In addition to making sure they adhere to the rules and regulations, firms are also concerned about the risks of data leakage, malware, and viruses. However, as new technologies have emerged to address regulatory and security challenges, financial service firms are demonstrating to their senior management that the risks of using social media may be mitigated.
What it all boils down to is this. Before engaging in any social media activity for your firm, be aware of the regulations surrounding social media in a professional services firm. Take them into consideration and demonstrate that you have taken a thoughtful approach. Put the review process into place. And most importantly, identify an influential principal of the firm who will champion the effort. It’s worth the effort. As firms slowly adopt social media within their distributed teams as a means to reach out to clients and customers, they are beginning to see increases in new customers and revenues that more than offset their initial concerns about the risks.
In an effort to distract myself from the heartbreaking impact of Hurricane Sandy across the New York and New Jersey area, I thought I’d do a bit of research on how regulators of the retail banking industry are handling social media.
As a former FINRA employee and an avid attendee of compliance conferences and events, I’m familiar with guidance from FINRA and the SEC for the securities industry. However, retail banking is governed by a whole other alphabet soup of federal authorities. Regulators include the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Consumer Financial Protection Bureau (CFPB).
However, like the securities industry, banks are interested in using social media to provide a personal touch to their customers. Even the Office of the Comptroller of the Currency recently ceased paper distribution of news and issuances in favor of email, Facebook and Twitter.
In response to the retail banking industry’s request, the Federal Financial Institutions Examinations Council (FFIEC) is coordinating the activities of these multiple federal banking regulators to craft social media guidance. FFIEC plans on publishing these guidelines in the Federal Register before the year’s end. If you are not familiar with the FFIEC, the Council was established in 1979 to promote uniformity in the supervision of financial institutions.
A source at the Office of the Comptroller of the Currency (OCC), says that once guidance is published in the Federal Register, the FFIEC expects substantial feedback from the industry and will accept comments for sixty days. From what I hear, the guidance will describe how existing rules and regulations impact social media. And as the members of FFIEC recognize the rapidly shifting nature of social media, they are trying to avoid specific recommendations. Their intent is to offer principal-based guidance that may be useful over time. Guidance may include, but, not be limited to interpretations of rules regarding Deposit Accounts, Consumer Lending, Payment Systems, Truth in Savings, Disclosures and more.
Don’t want to wait until possibly Spring of 2013 to get started? Those who wish to proceed with social media now, may want to begin to interpret how existing rules may impact the use of social media at retail banks. For example:
- individuals need to be verified as customers for advice to be provided
- liking or retweeting certain articles may be seen as “providing investment advice” and subject to review
- marketers to comply with advertising guidelines to avoid misleading or inaccurate communications
- disclosures need to be considered
- records of electronic communications require retention
- and privacy, confidentiality and customers’ data needs to be protected.
Additionally, there are also wider regulatory concerns such as Gramm-Leach-Bliley Act (GLBA) , Red Flag Rules and Privacy of Consumer Financial Information to work through.
While you wait for Federal Financial Institutions Examinations Council (FFIEC)’s guidance, you might also find it helpful to read what regulators within the securities industry are saying. We’ve found that guidance from regulators (FINRA, SEC, IIROC, FSA, SEBI) tends to fall along similar lines: social media is considered as just another form electronic communications and should be treated as such.
FINRA Regulatory Notices:
- 10-06 – Social Media Websites Guidance on Blogs and Social Networking Web Sites
- 11-39 – Social Media Websites and the Use of Personal Devices for Business Communications
- 12-29 – Communications with the Public
- FINRA’s Guide for the Web for Registered Representatives
Securities and Exchange Commission-
Although this seems like a lot to wade though, you’ll see it’s worth the effort. Financial institutions that deploy social media are reaping the rewards of enhanced customer service at lower costs, broader brand recognition and an increase in new accounts and revenues.
On a personal note, as compliance in retail banking is a new area for me, I particularly welcome your insights. I would also welcome suggestions for additional resources for me to read or conference or webinars to attend. And finally, here at Actiance, we’ll be drafting a White Paper on regulations for the Retail Banking Industry. Look for that soon.
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.
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.
Recently, the SEC issued some guidance that potentially places an additional disclosure burden on public companies. Given technology’s influence in the world of finance and business operations in general, the SEC deemed it an opportune time to issue its thoughts on the role of cybersecurity. It hasn’t been codified yet as a rule, regulation, or statement, but it is indicative of SEC sentiment towards the topic.
With the proliferation of communications channels in use today (think email, instant messaging, Skype, social media, to name a few), this also increases the number of potential avenues for cybersecurity breaches to occur. The ability to easily post content, such as links, videos, podcasts, audio clips, etc., makes these new communications vehicles inviting targets for hackers and other folks with malicious objectives.
So, it makes sense indeed for the SEC to worry about the impact of security breaches on a company’s operations and ultimately its bottom line, which in turn, means it should be disclosed in a 10K. It could very well be that a significant part of a company’s business depends on protection against cyber attacks. For instance, a data center provider must ensure it has the highest levels of security in its buildings and IT infrastructure to ensure that its customers’ data and/or equipment is secure. A breach in the provider’s network will directly affect the performance and fortunes of its customers who rely on near 100% availability, if not 100%, to conduct their own businesses.
And the SEC took it one step further by saying that companies must be specific in their disclosures and not use such generalized language that it can apply to any company. 10Ks are already notorious for reading like soporific legal documents, filled with boilerplate language, but the challenges faced by e-commerce sites might differ from those encountered by social media sites. That’s just one example.
The complexity of cyberattacks and the sophistication of their perpetrators necessitate detailed information in disclosure reports. That’s not to say that a company should compromise its own cybersecurity, but it should at least provide enough information in the 10K to inform a prospective investor the unique security risks that company faces.
In light of the financial scandals and instabilities over the last ten years, investor protection should not be taken lightly. Thus, it’s commendable that the SEC is taking another step in ensuring investors are afforded all relevant data points to make informed decisions. Bravo.
The amusing case of the Securities Exchange Commission (SEC) putting the smackdown on two gentlemen who likely were feeling nostalgic over their days swilling Pabst Blue Ribbon (PBR) beer illustrates how powerful social media has become. Michael Migliozzi and Brian Flatow, a couple of advertising executives, used Twitter and Facebook to secure over $200 million in pledges to buy Pabst Brewing Company, the makers of PBR. Their intent was to offer shares in the acquisition vehicle to those who pledged money.
Problem is that Sudsmeisters Migliozzi and Flatow didn’t file any registration papers with the SEC to sell such an offering. They ultimately yielded to the SEC’s cease-and-desist order, but the lessons learned were all too clear: (1) social media’s a quick and effective way to rack up $200 million in pledges in just three months, and (2) the SEC is watching. Yes, the SEC may be a government agency, but at least, it’s doing its best to stay current on trends falling within its scope, applying old-school analysis along the way.
Yup, we here at Actiance keep tabs on cases like these since it seems inevitable that social media-related cases will become standard fodder for SEC enforcement actions. Just as their FINRA brethren are blazing the trail with respect to social media-specific regulatory guidelines for broker-dealers, the SEC is following close behind on matters dealing with securities and investment advisory services. FINRA has already issued its seminal social media-specific disciplinary action in what is sure to be the first of many.
As social media continues to entrench itself in our daily lives, both personally and professionally, the regulatory watchdogs will become ever more vigilant to ensure that their guidelines are adhered to. Or, put another way, social media is the girl that every guy wants to take to prom, but that doesn’t mean that her father isn’t lurking far behind, baseball bat in hand . . . and a PBR in the other.
Whoever thought that government regulatory bodies were out of touch in our 2.0 world, best reconsider their position. The Securities and Exchange Commission (SEC) has begun to issue letters, asking investment advisors for details on their use of social media. The request is quite broad, covering documentation on messages, posts, tweets, blogs, record retention policies, and even how the firm in question treats the personal use of social media while on the corporate clock.
The goal ostensibly is to get a better understanding of how social media is being used within the financial services community. Every man and his dog knows social media is a hot topic these days, and the SEC is all too aware that the phenomenon has infiltrated broker-dealer and investment advisory firms as well. Financial advisors are keen to use social media to prospect for new customers, strengthen ties with existing clients, and to market new products and services. However, these communications between financial advisors and their clients are subject to regulatory scrutiny.
In January 2010, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 10-06, which was specifically written for social media. It spells out the guidelines securities firms must follow when communicating with clients. Reflecting the speed at which social media moves, FINRA already has plans to issue updated guidance later this year, conceding that many things they observed in 2010 were unexpected (e.g., at the time of original publication, brokers were not using social media for business communications). Such a miscalculation on FINRA’s part has forced it to revamp the guidelines.
And, it’s not just the US that is adopting measures to address social media. The Financial Services Authority (FSA) in the UK requires that appropriate risk warnings be given when social media is used for advertising purposes. Hand in hand with the increased regulatory interest in social media is the emergence of technology vendors stepping in to help firms remain compliant with these guidelines.
Here at Actiance, we’ve developed the industry’s most robust platform for managing and securing social media use within the enterprise. Our Socialite platform enables organizations to moderate, log, and archive all activities and content posted to Facebook, LinkedIn, and Twitter. In this way, financial services firms can rest assured that their communications with clients and prospects do not run afoul of any FINRA or FSA regulations.
Actiance is at the forefront of managing social media within financial services firms and will be providing guidance at headline Finextra events in London and New York over the coming months to share a best practice approach on coping with the regulatory guidelines.
The announcement last week that financial services behemoth, Citi, was looking for an attorney to oversee its social media activities underscores the influence that social media holds in today’s business world and the still-evolving legal ramifications stemming from ill-advised usage of social media tools. No industry is further ahead on social media guidelines than the financial services industry. The Financial Industry Regulatory Authority (FINRA) issued social-media specific guidelines in January 2010. Known as Regulatory Notice 10-06, these guidelines specify what types of social media content needs to be monitored and archived. The Financial Services Authority (FSA) in the UK followed soon thereafter with its own guidelines on social media, illustrating that the explosion is taking place on a global level.
Other industries are taking a cue from financial services, too, and have either started to issue guidelines on social media (e.g., energy and utilities) or are in the process of issuing them (e.g., pharmaceuticals). Even individual states, like Florida, have updated their General Records Schedule to require the retention of social media communications. The bottom line is that regulators are keen to keep pace with the dynamism of social media and are trying to establish frameworks for managing social media activities for their respective industries.
In the case of Citi, they’ve taken it one step further by initiating a search for an associate general counsel to focus solely on social media. Among the many responsibilities of this new role are protecting Citi’s intellectual property, working with specific business counsel to secure approval of content, establishing consistent processes for vetting and replying to comments in interactive environments (e.g., Twitter, Facebook, etc.), and promoting consistent policies.
The fact that Citi has created a role just for social media shows just how seriously the Wall Street giant is taking the phenomenon and is taking a proactive approach to establishing itself as the leader in this nascent practice area. Take, for instance, Anna O’Brien, the VP of Social Media at Citi. She’s credited with helping Citi become the first financial services company to have a verified Twitter account and is (obviously) a huge advocate of social media. She spoke at the Business Development Institute (BDI) conference in NYC a couple weeks ago about how social media is a powerful marketing weapon. Then, you’ve got the folks at Morgan Stanley Smith Barney, who have been championing social media as an effective marketing and prospecting tool for financial advisors. Morgan sees a well-defined social media strategy as critical to delivering on clients’ needs and expectations.
And it’s not just Social Media attorney titles that we’re seeing. More and more often we’re starting to see the appearance of titles like Social Media Compliance Manager and Product Manager Social Media on job boards. In fact, when one does a search on LinkedIn for “social media compliance,” nearly 13,000 people turn up in the search results here in the US. So, Citi and Morgan Stanley are not alone is recognizing the importance of social media.
As the conversation moves from our email clients to the social network, Gartner suggests that for 20% of us business users, social media will become the primary mechanism for interpersonal communications by 2014. Here at FaceTime, we see an increasing amount of content passing through these social networking sites. This may be daunting, but platforms such as Socialite help firms, particularly those in regulated industries, remain in compliance with the emerging guidelines specific to social media. From pre-review moderation of content to the contextual logging and archiving of activities and events, FaceTime can enable folks like Citi’s associate general counsel-to-be execute his or her job duties with more peace of mind.
10-06, anna obrien, banks, BDI, Business Development Institute, Citi, facebook, FaceTime, finra, Florida, FSA, Gartner, general counsel, general records schedule, GRS, job title, Morgan Stanley Smith Barney, Regulatory Notice, sec, social media, socialite, Twitter
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