Social media is challenging financial firms as they try to determine what they can say, to whom and how much—and whether, and how, to review the content of any social media communications. Socialware has come up with a graphic that simplifies FINRA’s three notices and many pages of guidance on the subject.
While pointing out in his blog that “we are seeing very consistent approaches as it relates to content policy,” Chad Bockius, CEO of Socialware, reminds everyone that “your firm may ultimately decide to go another direction based on factors beyond the regulatory guidance” and that above all, you should make sure that “your firm’s method and policy should take a risk-based approach.”
Three questions, he says, offer clues as to whether material for inclusion in social media communications needs either a pre- or post-use review. They are:
- Is the content static or interactive?
- Does the social network update (a tweet, status update, etc.) contain a link or not?
- If it does contain a link, is it business related?
The last question, he says, is the most critical, since it can trigger “regulatory requirements around adoption, entanglement and the measure of whether or not the information shared is fair and balanced.”