Before Blogging to the Public, Blog to the Compliance Department First
Alrighty. So now that you’ve read my two blog posts about why wealth managers should blog and how FINRA’s social media rules apply to the SEC’s, in this post I’m going to give you some tips on how wealth managers can make their blog content fall in line with those regulatory mandates:
Social Media Policy – All wealth managers that decide to go online should first have a social media policy firmly in place. What parameters it outlines is ultimately up to the firm, but it should clearly address who at the company is authorized to publicly speak on social media sites on behalf of the company. It should also provide guidelines on what is considered appropriate employee behavior on social media platforms. Lastly, it should also be directly communicated to all employees, along with a recorded confirmation that they have read the policy.
Compliance Review – The wealth manager should establish a process for Compliance-approving all social media content. Let’s say a wealth manager has a resident financial expert that is a gifted writer. Per the firm’s social media policy, the firm authorizes the expert to write on behalf of the firm on the firm’s blog. The expert then writes a compelling editorial. Before publishing the editorial, the expert should first send the verbiage to the firm’s Compliance department for review. The Compliance department will then read over the content to make sure that no regulatory rules are violated in the editorial’s content. Once reviewed, the Compliance department might approve the piece for publishing, or require the expert to make a few changes to the verbiage before it gets published. The Compliance department should then record this review and archive the editorial. Once the review process is complete and the expert has the green light to post from Compliance, the expert can then post the editorial online.
Automated Archiving – Compliance record keeping should not end at step two, however. It is a good practice to track and capture all online activity, whether it is blog posts, comments, pictures, tweets, video, email, etc. Doing this manually will eat up a lot of time, memory and money. Outsourcing this archiving, on the other hand, will make this process much easier and affordable. There is an assortment of professional social media archiving companies that use innovative applications to automate the tracking, capturing and saving of all company-produced online content.