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Overview. Regulated Communications Static Social Media Content Interactive Social Media Content The Problem with Third Parties General Considerations for Social Media Policies and Procedures.

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overview
Overview
  • Regulated Communications
  • Static Social Media Content
  • Interactive Social Media Content
  • The Problem with Third Parties
  • General Considerations for Social Media Policies and Procedures

Image credit: http://www.globallegalpost.com/blogs/management-speak/the-law-firm-social-media-solution-5582988/#.ULZbn4b5Urc

communications review supervision and record keeping
Communications: Review, Supervision and Record-Keeping
  • IIROC Rule 29.7: Advertising, sales literature and correspondence
  • NI 31-103: General Record Keeping Requirements
  • Pre-review and approval
  • Post-use review and/or sampling
  • Record Retention
social media subject to iiroc rules and securities legislation
Social Media Subject to IIROC Rules and Securities Legislation

Communications via social media are subject to Dealer Member Rules and securities legislation, “regardless of the method by which communication takes place, and however social media websites evolve…”

classifying communications
Classifying Communications

Static Social Media Content

vs.

Interactive Social Media Content

static social media content
Static Social Media Content
  • Wall, background and profile information
  • Akin to template advertising
  • Requires pre-review and supervision
interactive social media content
Interactive Social Media Content
  • Instant messaging
  • Facebook wall
  • Comments
static and interactive content
Static and Interactive Content

Static Content

Interactive Content

the problem with third parties
The Problem with Third Parties

User:Hey – what are you up to?

Approved Person: Oh hey! I’m just working on a blurb to submit to my boss describing my work experience for some PR pamphlet the office is putting together. Mind taking a look for me for typos/style before I submit it for approval?

User: No problem – just copy/paste it in and I’ll look at it right now.

Approved Person: Approved Person brings a wealth of experience and insight in the market to clients, and can guarantee a rate of return of 10%/year on client’s investments

the problem with third parties1
The Problem with Third Parties

User: Hey – what are you up to?

Approved Person: Oh hey! I’m just working on a blurb to submit to my boss describing my work experience for some PR pamphlet the office is putting together. Mind taking a look for me for typos/style before I submit it for approval?

User: No problem – just copy/paste it in and I’ll look at it right now.

Approved Person: Approved Person brings a wealth of experience and insight in the market to clients, and can guarantee a rate of return of 10%/year on client’s investments

Screen

Capture

the problem with third parties2
The Problem with Third Parties

Approved Person: Approved Person brings a wealth of experience and insight in the market to clients, and can guarantee a rate of return of 10%/year on client’s investments

permitted users
Permitted Users
  • Training
  • Compliance History
  • Ongoing Supervision
which platforms
Which Platforms?
  • Privacy Policies
  • Ability to control and delete user content
  • Ability to control and delete third party content
  • Record-keeping

Image credit: http://www.floodlight.ca/internet-marketing-kelowna/social-media/

from where
From Where
  • Firm-owned devices
  • Personal computers
  • Smartphones
  • Supervision
  • Record-keeping

Image: http://tommytoy.typepad.com/tommy-toy-pbt-consultin/2012/10/while-smartphones-have-reached-critical-mass-tablets-are-poised-to-do-the-same-soon-as-a-form-factor-tablets-simultaneousl.html

slide17
How
  • Regulated communication
  • Permitted communication
  • Third party communication
  • Supervision
  • Corrective Action
  • Record Keeping

Image: http://www.smartpassiveincome.com/blog-post-checklist-after-publish/