One of the most frequent topics of discussion as it relates to social media and financial services is content. Questions range from “what can I post?” to “what needs to be pre-reviewed?” and “what can be post-reviewed?” The questions seem to be never-ending. The good news is these questions have all been answered and the content conundrum should not paralyze you or your firm.
Before going any further it is worth reminding our readers that your firm’s method and policy should take a risk-based approach. While we are seeing very consistent approaches as it relates to content policy, your firm may ultimately decide to go another direction based on factors beyond the regulatory guidance.
Over the last few years FINRA has been hard at work to provide the industry with as much guidance as possible. The details in Notice 10-06, Notice 11-39 and Notice 12-29 provide us the guidance we need to make the appropriate supervisory decisions as it relates to content. To uncover whether or not social content needs to be pre or post-reviewed ask yourself the following:
- 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?
This last question is critical as it triggers regulatory requirements around adoption, entanglement and the measure of whether or not the information shared is fair and balanced. Of course, the fair and balanced standard ONLY applies to business-related information, not to the latest article from ESPN or recipe from Food and Wine. Now that you have a solid understanding of the supervisory requirements for content, next move on to thinking about your content strategy. Here are a few questions to get you started.
- What types of content will you enable for your field force?
- How much content will you provide each month?
- How frequently should your field force post?
- Which sources of content will you make available?
- How will you measure the effectiveness of that content?
- How will you pre-review content like social networking profiles?
- How will you distribute approved content?
- How will you measure the effectiveness of the content?
These are just a few of the questions to consider as your work through your strategy. We hope they help. So tell us, where does your firm stand on deploying a content strategy? What obstacles are holding you back? Download the infographic, and we’d love to hear from you.