“Your call may be recorded. . .”

We’ve all heard this countless times, but we usually yawn and consider it an afterthought.  But, for those folks working in regulated industries, these words ring true.  In the UK in particular, there are strict guidelines on the recording of voice calls.  For instance, the Financial Services Authority’s Policy Statement 08/1 specifically requires firms to record all relevant telephone conversations and electronic communications.  And even if the requirement does not explicitly single out voice recordings, it is certainly implied in the “electronic communications” language adopted by the SEC, FINRA, the FRCP, and others.

Additionally, even though there’s a marked trend of moving away from legacy PBX systems towards VoIP systems, this doesn’t make the recording requirement go away.  If anything, it highlights the importance of having to record conversations in whatever format they take place in.

These days, communications could be over unified communications platforms like Microsoft Lync, social media, instant messaging,  mobile phones, or even the good ol’ landline.  It’s just that the rapid adoption of Microsoft Lync over the last few years has shined the spotlight on voice calls through this specific platform.

Lync adoption in general has been spurred by the increasing demand to cut costs and enhance productivity in the workplace.  PBX systems are more expensive and difficult to manage, which only serves to expedite the transition to IP-based systems like Lync.  Easier expansion and greater flexibility are also prompting organizations to switch to Lync.

But oftentimes, before organizations can even deploy Lync, they need to ensure they’ve got a management solution in place to provide the compliance and security capabilities that’ll give them the peace of mind they need before deploying Lync.  That’s because native Lync functionality is insufficient to keep companies from fully adhering to the governance requirements they’re subject to.

Actiance Vantage removes these roadblocks by making it possible for firms to securely record Lync Voice calls in accordance with applicable compliance requirements.  All key metadata is captured; data integrity is verified; and there’s integration with a wide range of archiving platforms.  Throw in support for other Microsoft applications (SharePoint, Skype, OCS) and non-Microsoft applications (Jive, IBM Connections, Google Talk, Yahoo! Messenger, Bloomberg, etc.) and it’s easy to see why Vantage is considered the marquee governance solution for the broadest range of communication channels.

By taking care of the governance aspects, Actiance enables organizations to focus on their business.

Belbey Blogs: Upcoming Guidance for the Use of Social Media for Retail Banking from FFIEC

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-
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-

• National Examination Risk Alert Investment Advisor Use of Social Media

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.

The Demise of the FSA and the Future of Financial Promotions

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.

FINRA 11-39: Applause, Missing Pieces, and Users

In the week that “retweeted” was officially added to the Oxford English Dictionary, after only two years of use, FINRA beats the retweet and issues new guidelines on social media, just 18 months after 10-06 hit our doorsteps, and “So, what do you read into 11-39?” is the question on the tip of everyone’s tongue.

As expected, a few points are clarified; the latest guidance has become more prescriptive in some areas and less so in others.  (Puzzled looks abound, I’m sure.)  If you’d rather hear more about this, than to continue reading, please join me on a webinar Wednesday, August 31st at 10am EST and I’ll explain.

I’ll start with the missing pieces of 11-39

What’s missing is the specific reference to individual social networking sites (I bet that’s not what you were expecting).  And for this, I applaud FINRA.  Examples were given in 10-06 – Facebook was mentioned twice (OK, three times if you look at the endnotes), Twitter four times, and LinkedIn just the once.   Interesting that, in the conversations I’ve had with wealth management firms and wire houses, it’s LinkedIn that is the network of choice.

Why my applause though?  Good job, FINRA, I say, because you’ve recognized that this world moves very quickly.  Three months ago, YouTube was the fastest growing social network.  Then it was Google+.  And now, as Google+’s new member growth falls by 30% a day to 700,000, we’re not sure anymore.  That said, LinkedIn has added 20 million new profiles since its IPO in May and now boasts 120 million profiles.  Equally, since January 1, 2011, we’ve tracked 938 changes across Facebook, LinkedIn, and Twitter (yes, really!).

Good job, FINRA, because you’ve recognized that loyalty in our social world is somewhat limited.  And, that just because Facebook, LinkedIn, and Twitter are today’s Holy Trinity of social, it doesn’t necessarily mean that they will be tomorrow.

What else is good?

It’s also good to see clarification on business versus personal commentary – this reinforces what we’ve been saying for some time, that “the regulator is interested in the communications related to the business and when the individual is representing the business” – the advice we have been giving since January 2010, is NOT to go against the Facebook rules (for instance) and set up two profiles, but take advantage of Facebook giving you the ability to set up a profile for personal use and a page for professional use, because contrary to a lot of public opinion, you CAN do this – as a businessperson, you can set up a specific page for your business use (drop me a note if you want step-by-step instructions).  The SEC itself has stated that the content of an electronic communications determines whether it should be preserved.  Just like the FSA out of the UK does.  It doesn’t matter about the modality.

I do believe that, as an industry, we are perhaps being somewhat short-sighted by thinking that you can absolutely separate  personal from business communications in the social world.  I think the lines will continue to blur (increasingly so) as we become more accustomed to social.  I do believe we’ll see more guidance on this as time goes on.

What else is new? 

A proposed social media site must be approved in the “form in which it will be launched.”  FINRA is talking here about the launch of new social media sites.  So, if you’re launching a new design, a new Twitter feed, for instance, then the graphics that you’re using, the imagery, and the actual site – the “wireframes” in design parlance – need to be part of the approvals process.  Third Party Data Feeds are referenced also.  FINRA reminds us that the firm is responsible for checking the proficiency of the vendor of the data and its ability to provide accurate data – and it must regularly review for red flags.

Don’t Delete!

In reaction perhaps to the number of new companies popping up purporting to provide control and manage social media, FINRA specifically calls out details on technology that automatically erases or deletes content, stating that this precludes the ability of the firm to retain the communications in compliance with their obligations under SEA Rule 17a-4, yet further into the 11-39 guidelines, FINRA details more about the deletion of inappropriate third-party content.

It’s clear that a record of communications that doesn’t contain the full record is no record at all.  However, I do hold to the fact that some content simply has to be deleted.  I can’t control the 750 million other Facebook users out there (heck, I can’t even control what my little brother says on Facebook), and not all of those users have the same filtering mechanism that I have when it comes to content.  I’ve deleted some friends and banned others because their language would offend my Mother, who to me, is my ultimate Facebook controller.  In a corporate environment, I certainly don’t want the Actiance brand associated with profanity, racism, or a host of other comments, that we automatically delete through the use of our Urban Dictionary.

But we do record the fact that they were made.  We also record the fact that they were deleted.  We also record what the page looks like before and after the delete.  Belt and braces.  It might not be on the social network anymore, but it’s in the archive.

Mobile IS mainstream, and network barriers have crumbled.

And, it’s clear to see that the growth of mobile is having an impact; 250 million of the 750 million active Facebook users use the site through a mobile device – and on mobile, they’re twice as active.  It’s clear that firms are concerned about mobile, rightly so, but equally, that FINRA is being sensible about how firms operate and how they do business.  And, not all of us use devices that are firm-owned to post content and collaborate on social networks.  That’s the way the world is changing.  It’s one of the biggest challenges of today’s CIO:  the personally owned device (whatever that might be – iPhone, BlackBerry, Droid, iPad, Tablet, Netbook).  FINRA reminds us that it’s the communications, not the device, that is important.

The Users, the pesky Users…

FINRA gives an even bigger call-out about training and education.  Human beings, I’m convinced were put on earth to create chaos.  And in a social world, we can do this very quickly and very easily.  (I should at this point, before our CEO, @Kambwani, sees this, reference that this quote is mine and mine alone.)  But equally, you don’t just give 20,000 financial advisors access to LinkedIn and expect that they know what to do.  In a lot of instances, there is a generational gap, injecting social into the DNA of individuals doesn’t happen overnight.  FINRA is dead-right by saying that training is important, that certification is important.  And regular training is not just a one-off, because people forget when they’re on a social network.  They forget who they’re connected to, and who might see their content.

We are, after all, as human beings, ultimately fallible.  And, we have technology in every other area of our business lives to protect us (anti-spam and security in the email world), to stop us sending our bank account details to Nigeria or our intimate personal details to hackers, Web filtering in the Web world to stop us playing online poker all day, and maybe even Actiance to limit our usage of Farmville to a mere 30 minutes a day.  In other words, we use technology to protect us against technology.  And it goes without saying that using technology to protect us from malware infection (our very own @jaeho9kim wrote about this recently right here on this blog), from ourselves, and from malicious intent.

I think I’ve rattled on quite long enough now, so I’ll leave you with this final set of questions.  Did 11-39 answer your questions?  Did it raise more?  What do you think it didn’t cover?  Tune in next week for our webinar – and for thoughts that I’ve gathered recently, when I got together with 60 Financial Services Marketing, Compliance, and IT professionals and asked them what they thought FINRA should issue in terms of guidance.

The Watchdog Is on the Prowl

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.

Step aside. There’s a new social media sheriff in town…

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.

The Headmaster Has Spoken

On November 11th, the United Kingdom’s Financial Services Authority (FSA) announced that, starting in November 2011, mobile phone conversations by traders and other client-facing staff will have to be recorded (Policy Statement 10/17).  Specifically, firms have to record all “relevant conversations” for a period of six months on company-issued phones.  This new rule is designed to prevent market abuse and insider trading across the trading spectrum, including commodities, OTC instruments, futures, options, and ETFs.

Although at first read, it sounds draconian, when evaluated against the myriad accounting scandals and financial crises of the past fifteen years, the new rule makes sense.  It really is just an extension of firms’ existing practice of recording landline calls.  Whether it’s for risk management, dispute resolution, or compliance purposes, the need to record calls (whether landline or mobile) is real.  These days, brokers and traders have numerous communications channels at their disposal.  There are landlines, mobile phones, instant messaging, SMS, social media, peer-to-peer, and the list goes on and on.  Yet, their end goal remains the same:  execute deals, make money, clock fat bonuses.  Doesn’t matter what communications modality they use.  The raison d’etre of financial services firms is to make money.  Simple as that.  Any controls and regulations that are there to prevent global catastrophes, such as what happened in the fall of 2008, need to be evaluated objectively and with foresight to ensure that they meet current and future requirements.

Enter Policy Statement 10/17.  Although some firms have shown resistance to this new rule, it really is a natural evolution of the increasing regulatory control over these new real-time communications channels.  In the US, the Financial Industry Regulatory Authority (FINRA) has issued social media-specific guidelines (e.g., Regulatory Notice 10-06) for its 4,700 member brokerage firms and 637,000 registered securities representatives.  The explosion of sites like Facebook, LinkedIn, and Twitter is taking the mobile phone one step further.  They’re just another communications option for brokers and dealers to exploit.  If a broker is tied up in a meeting and can’t chat on his or her phone, he or she can simply SMS, IM, or use Facebook to send a message.

Although PS10/17 may seem like the ornery ol’ Headmaster wielding a big stick, it’s simply a reflection of the ever-changing dynamics in the communications landscape for financial services firms.

“It’s compliance Jim, but not as we know it”

From Robin Smith, Technical Manager, EMEA, FaceTime Communications

I recently read an article posted on The Register, based out of the UK, about the great advances the current version of Microsoft’s Unified Communications platform (OCS) has made, when compared with previous incarnations. I’m in full agreement and look forward to the next release, currently called CS14, details can be found here. Given that a large number of our customers have either industry or legal compliance requirements they must comply with, I did feel one of the final comments needed a little more qualification than space in the article allowed for:

“…if compliance is a concern, you have IM archiving”

The moment I read that, I was catapulted back to the late 1980s and ever since haven’t been able to get the incredibly annoying “Star Trekkin” by “The Firm” out of my head. Click here or search YouTube for “The Firm – Star Trekking” if you have no idea what I’m talking about – your ears won’t thank you. Why? Well, compliance is in the eye of the person with a fine and possible jail sentence hanging over their head and as Spock’s line in the song goes:

 “it’s life Jim, but not as we know it.”

There are in fact a few different ways you can store OCS IMs both natively with Microsoft products and using third-party solutions. But, as those who write on bits of paper or print things out so they don’t forget or lose them and then can’t find the bit of paper when they actually need it can attest to, just because you’ve archived something doesn’t mean:

• you can ever find it again, even though you know it’s in that pile somewhere
  
• it will be complete, maybe the dog ate half of it
  
• that it will come back looking the same, maybe you spilled coffee on it or you printed out several pages and they’ve been mixed up so the order is wrong
  
• that someone else can look through the pile and find the piece of paper
  
• different things of difference genres or sizes will fit or stay in the pile properly
  

To achieve all of the above, you need special controls around how you capture, store, search and recover data.

You need to be able to show that what has been recovered is the same as what was originally stored and that it is a true representation of the original data. You should also make sure that in the case of a multi-party chat where someone wasn’t part of the whole conversation that the view of their data is different to that of the other participants’. Let alone the ease of use issues around eDiscovery; making it possible for someone (often non-technical) to search the archive and recover what they need without having to become an expert in SQL scripting. So if we can achieve that, are we compliant? Maybe, maybe not.

What about usage policy? Can my Traders and Research teams talk to each other? Do I want Billy in the call centre using my OCS system to ask all the eligible young ladies in the department out on dates?

What about content security? If I’m allowing file transfers, shouldn’t they be stored along with the IM conversation transcripts? Shouldn’t you be virus checking file transfers, making sure that staff aren’t using inappropriate language over IM, especially with business partners through my OCS edge server.

My point is that for some people compliance isn’t just about storing what happened, it’s about making sure certain things can’t happen in the first place and being able to retrieve it in a fashion that meets regulatory requirements.

“There’s Klingons on the starboard bow”


The list goes on…and we haven’t even thought about what else is happening on the corporate network. What about Skype, Yahoo, GoogleTalk , Windows Live Messenger and Blackberry PIN / SMS to name but a few?

Of course the OCS Archive server wasn’t designed to be an enterprise platform covering so many different flavours of IM – but it is rare to see just one flavour of Instant Messaging on a corporate network. From a management perspective alone it makes sense to have a consistent policy around all authorised channels and block everything else.

…and finally, there’s the whole issue surrounding Social Networking. “We block it”, I hear you say. Well, that’s all well and good, but last time someone told me that I searched Twitter and found no less than 5 accounts tweeting on behalf of the company. I then searched Facebook and found a network, groups and employees.

Couple this with the huge pressure many companies are under to enable sites like Facebook, LinkedIn & Twitter for legitimate business purposes along with the reach it gives sales and marketing for the company’s brand and you can see why there’s such a lot of noise in the corporate space surrounding Social Networking.

Ask FINRA (Financial Industry Regulatory Authority) or the UK’s FSA (Financial Services Authority), both have issued specific guidelines regarding social networking posts, saying that they need to be treated as forms of electronic messaging. This means that they effectively need to be subject to the same controls mentioned above.

So. Yes, you can indeed store your OCS IM conversations in the OCS Archive server. Does it give you IM compliance? Not as we know it, Captain.

Robin J Smith is FaceTime’s Technical Manager for EMEA, an occasional Star Trek viewer and is currently looking for suggestions on how to get the above song out of his head. You can follow him on Facebook, LinkedIn or Twitter.