1. Social Media Compliance
Social Media Basics Webinar Series

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 Have the rules changed?
 How are advisors using social media?
 What are the most effective strategies for engaging prospects and clients through
social media?
 Highlights from Arkovi Client Research
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3. Compliance—Rules Changed?
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The Rules Haven’t Changed—The Mediums Have!
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4. Compliance Definitions
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What’s New?
 Reduces six categories of communications to three
FINRA 12-29
(Feb 2013)
‒ Institutional
‒ Retail (advertising resides here)
‒ Client and/or firm correspondence
Pre-Approval
Tweaks For
Exceptions
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 If pre-approved by another firm—no need approve again
 Posting to “online, interactive electronic forum”—
ambiguous but points to social platforms
 Content that offers no financial or investment advice

5. The Compliance Landscape
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Guidance from FINRA & SEC—2010 through
2012
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Coming Soon—FINRA 12-29 (February 2013)
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Best Practice:
 Social Media Policy
 Archive Content and Engagement
 Reporting and Monitoring Tools
• Compliance AND listening +
intelligence
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6. Don’t overlook the obvious
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7. Social Media Policy
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We work with your compliance department
to write and develop your FINRA compliant
social media policy.
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8. Social Media Policy Best Practices
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Define and Document Your Policy
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Which platforms are acceptable?
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Include your own governance and
ethics
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Approved technology
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Signed affirmations
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Mitigation
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Who is authorized?
Ongoing management

9. Rules & Regulations
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•FINRA 10-06, 1139, 12-29
•NASD 3010
•NASD 2210 (b)
•SEC 17a4
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10. What Did FINRA Tell Us?
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•Twitter, Facebook and LinkedIn are like traditional written
communications
•Additionally
-Websites = advertisements
-Communications to 25+ prospects = sales literature
-Password-protected websites = sales literature
-Chat room discussions are public appearances
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11. NASD 3010 & 2210 (b)
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•The obligation to review correspondence
-Supervisory role of surveillance
-Retention of all material (even non-reviewed) to avoid surprises
•Moderation
-The ability to moderate & pre-approve per
2210 (b) as needed with audit trail
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12. SEC 17a4
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•Records Retention
•Indexing and Retrieval
•Verification and Time-Stamping
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13. Our View of the Rules
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© Arkovi 2011
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14. Defining How Business Uses Social
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15. The Gateway to Social Media For All
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 Tablets
 Smart Phones
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16. Social Media – Listening and Observing
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 Track topics important to you
– Track web and social alerts
– Use a single view
– Identify clients, peers, influencers & connect
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Monitor what others say about you
– Your brand and products/services
– Your company
– Your employees and partners

17. How Do We Avoid Pitfalls?
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With a plan…
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Plan for the best way to use social media
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Plan for integration to all communications strategy
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Plan for the rules
Plan how you can start

18. Getting Started: Defining Your Strategy
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Have a strategy for:
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Executive and team support
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Match the medium(s) to your firm culture
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Resources—listening and compliance
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Content plan—editorial calendar
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Plan for negatives
It is the “wrapper” around your social media policy.
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19. Social Media Basics Webinar Series
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