Belbey Blogs: “What are other firms doing?”

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

Last month, I was asked by a new client:

“How are companies with technology solutions in place to monitor/moderate/archive posts treating Registered Reps’ and captive agents’ ability to share updates and links on social media sites? Are they allowing them to do this?  Are they pre-reviewing activity in advance or sampling post-review?”

The answer?  It depends.

There is no one approach. And every firm takes a different approach.  However, in general, we are seeing three general approaches:

Posting Corporate Messages: At the most conservative end of the spectrum, some firms create centralized libraries of pre-approved content, including a series of introductory statements (updates, tweets, etc) and even craft responses to updates. Because social media never “goes away”, these firms interpret all social media communications to be “static” advertising and hence they pre-approve everything. Although not strictly required by FINRA, as Joe Price of FINRA recently told the audience at the FINRA Advertising Regulation Conference, “Each firm bases its social media use policies its risk tolerance. And that’s fine”.

Personalization: The majority of firms also create centralized, preapproved content libraries with a series of introductory statements. However, they interpret the interactive portion of social media to be akin to a public appearance and hence allow their registered persons to interact on social media in real time without pre-approving each post. However, they put controls in place to block certain “trigger” words (such as stock symbols, “guarantee” “buy”, “sell”) and post review a pre-defined percentage interactive communications to demonstrate supervision.

Authentic Voice:  A smaller group of firms take the personalization approach a step further. These firms create centralized, preapproved content libraries, with introductory statements, and block certain “trigger” words (as above) to allow for interactive communications. However, these firms also encourage their registered persons to craft their own introductory statements to preapproved content as well as to post their own content with controls in place to block inappropriate “trigger” words. And like above, firms post review a pre-defined percentage interactive communications to demonstrate supervision.

Do firms use a phased approach?

We have found that firms tend to pilot social media with tight controls in place and typically don’t allow registered persons 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.

Different Use Policies- It’s also effective to create and enforce different use policies for different categories of users. For example, financial advisors with clean compliance track records and who have demonstrated appropriate use of social media, may be allowed a bit more freedom than those who are new to social media or have problematic compliance histories.

What works best?

We have found that reps achieve the most engagement when their firms facilitate allowing the reps’ “Authentic Voice” to shine through. After all, don’t we prefer to do business with people who share our common interest and passions? However, although this approach requires training in best practices, and perhaps a bit of hand holding, it yields better long term results.

photo credit