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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.

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Overview

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  1. 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

  2. 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

  3. 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…”

  4. Classifying Communications Static Social Media Content vs. Interactive Social Media Content

  5. Static Social Media Content • Wall, background and profile information • Akin to template advertising • Requires pre-review and supervision

  6. Interactive Social Media Content • Instant messaging • Facebook wall • Comments

  7. Static and Interactive Content Static Content Interactive Content

  8. 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

  9. 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

  10. 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

  11. Social Media Policies and Procedures ? • Who • What • From Where • How

  12. Permitted Users • Training • Compliance History • Ongoing Supervision

  13. 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/

  14. 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

  15. How • Regulated communication • Permitted communication • Third party communication • Supervision • Corrective Action • Record Keeping Image: http://www.smartpassiveincome.com/blog-post-checklist-after-publish/

  16. Questions?

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