A cheat sheet to social media for financial institutions

 

Do you work with financial institutions?  Ever had someone ask you about social media regulations and stuttered your response?  Ever felt like, well, you aren’t exactly sure what they are or how they apply?   Were you that kid who wrote the test answers on your arm with a Bic pen?

FINRA issued Notice 10-06, its guidance on social media to its 4,700 member firms, in January of 2010 – almost a year ago.    If you are a compliance officer, you may have 10-06 memorized.  If not, you might be wondering – or you might sometimes forget – what it all boils down to.  That’s why we developed the following cheat sheet.

Without question, this does not cover the fine points of the guidance (and is not meant to be authoritative).  But if you are looking for a quick way to identify the “red, yellow and green lights” of social media for FINRA regulated businesses, start here:

Of course, there are still several gray areas.  Open questions remain that have not been worked out either by the guidance or generally in practice, including:

  • Use of mechanisms for content sharing – “share this” icons and social bookmarking.
  • Firm sponsored content on external social media sites.
  • Any differences in guidelines that apply to registered reps versus a member firm’s marketing/PR staff when posting social media content.
  • Whether pre-screening blog comments constitutes “adoption” and is therefore considered endorsement or approval of the comment.

Thanks in particular go to Catherine Sherwood and Socialware for their great writing on this topic.

What’s on your cheat sheet? What have we missed?  What’s unclear?

To reach Abby:

Phone: 212.840.0088
Email: abby@blisspr.com
Twitter: @abbycarr
LinkedIn: Abby Carr