Compliance & Regulation
32
For Advisor Use Only
March/April
2014
communication; however, this content is specifically
exempt from preapproval. FINRA Notice 10-06 similarly
speaks to the record retention requirements of social
media communications, which can be met if your profile
is registered with Erado.
Now that you’re aware of the differences between static
and interactive content, follow these brief steps to ensure
that you create a compliant social media profile:
1.
Create your profile using the appropriate disclosures.
Be sure to keep it private, so the public can’t see it
before it’s approved. (For detailed instructions, see
our how-to guides at My Practice > Marketing >
Building Your Brand > Website, E-Mail, & Social
Media Marketing on COMMunity Link.)
2.
Submit your profile to the Advertising Review team
for approval.
3.
Register your account with Erado.
A tip for the road.
When sending LinkedIn InMail
(permitted only for individual pages), remember
to use your preapproved e-mail signature for
business communications.
Additional information on setting up various social media
accounts, including best practices and compliance guidelines,
is available on the Website, E-Mail, & Social Media
Marketing page on COMMunity Link.
Don’t Get Pulled Over
In 2010, FINRA brought a case against an advisor, who
had failed to disclose her Twitter account to her firm, for
tweeting overly optimistic projections on future share
price increases. Her tweets lacked adequate disclosures
and were considered unbalanced communications,
resulting in a $10,000 fine and a one-year suspension.
Certainly, no advisor wants to get involved in a case like
the one above. If you find yourself unsure of how to
navigate this windy road, don’t go with the flow—use
the Compliance team as your traffic guide. Call x9603 or
e-mail
with any questions.
Julie Burgess is a compliance advisor. She is available at
x7156 or at
.
By 2025, it is estimated that 75 percent of the
global workforce will be Gen Y.
— Business and Professional Women’s Foundation
