Published on March 12, 2014
Social Media for Registered Investment Advisers Deb Tobin, Compliance Manager Financial Engines Advisors L.L.C. March 6, 2014 For overview purposes only. Information provided for evaluation and informational purposes only, and does not constitute and should not be construed as operational, inivestment, legal or tax advice. Financial Engines Advisors L.L.C. is a federally registered investment advisor and wholly owned subsidiary of Financial Engines, Inc. Financial Engines does not guarantee results and past performance is no guarantee of future results. Financial Engines disclaims any liability arising from your use of this information. Views expressed are as of today’s date and may change based on market and other conditions. Unless otherwise noted, the opinions provided are those of the speaker/author and not necessarily those of FE. CPY11006
2 Agenda Key Takeaways RIA’s – what’s all the fuss about? Investment Adviser Advertising Guidelines SEC OCIE Risk Alert What will it take to make it happen? Effective Governance Where do you want to go? Train….. train…. and train again We’ve arrived….. Now what?
3 Key Takeaways For marketing people: • Figure out what matters to Compliance • Learn the language • Communicate, early and often For compliance people: • Figure out what matters to Marketing • Learn the language • Communicate, early and often
4 RIA’s – what’s all the fuss about? Investment Advisers Act • Rule 206(4)-1 – The Advertising Rule SEC No Action Letters • Clover Capital Management, Inc., October 28, 1986 FINRA guidance • Regulatory Notice 10-06, Social Media Websites • Regulatory Notice 11-39, Social Media Websites and Use of Personal Devices for Business Communications
5 Investment Adviser Advertising Guidelines • No false or misleading statements • Do not make promises we cannot keep • Avoid absolutes • Testimonials are generally prohibited • Performance information • Cite sources • Use trademarks and service marks properly
6 SEC OCIE Risk Alert: Investment Adviser Use of Social Media, January 2013 Key Takeaways Investment advisers that use or permit the use of social media by their representatives, solicitors and/or third parties should consider periodically evaluating the effectiveness of their compliance program as it relates to social media. Factors that might be considered include usage guidelines, content standards, sufficient monitoring, approval of content, training, etc. Particular attention should be paid to third party content (if permitted) and recordkeeping responsibilities. Highlights • Usage guidelines Content standards & approval • Monitoring & frequency Firm resources • Training Criteria for approving participation • Certification Functionality • Personal/Professional sites Information security • Enterprise-wide sites
7 What will it take to make it happen? Crawl … Walk …. Run! Consider conducting a Risk Assessment • Current exposure • Firm level • Employee/rep level • Tools • Archiving • Monitoring • Resources • Training
8 Effective Governance Policy Creation and Management • Compliance, Legal, HR, Business, Technology • Committee structure Structure • Focused Social Media Policy • Combined SM Policy with Electronic Communications Policy • Combined SM Policy with HR Code of Conduct Policy Create a Social Media Strategy
9 Where do you want to go? Where are your customers? • Blogs • LinkedIn • Twitter • YouTube • Facebook General features • Profiles • Email, IM, Chat • Recommendations, Endorsements, Liking
10 Train….train…..and train again Who do we train? • Access persons • Licensed reps • Managers or supervisors • Compliance reviewers • All employees How often do we train? • Annual Compliance Awareness • Social Media training Other approaches • Attestations • Certifications
11 You’ve arrived! Monitor • Technology changes • New site features or enhancements • New sites Regulatory updates • SEC guidance • FINRA guidance Re-assess effectiveness and potential gaps Adjust approach Train again Now what?
12 Key Takeaways • Figure out what matters to one another • Learn the other’s language • Communicate, early and often
14 About Financial Engines Cerulli Associates, The Cerulli Edge—Retirement Edition, 3Q 2013; data as of September 30, 2013. Financial Engines, America’s largest defined contribution managed account provider*, is dedicated to making high-quality retirement help available to everyone — regardless of how much money they have. We’re proudly independent, which means we don’t sell products or earn commissions based on our investment recommendations. The companies that choose to work with us offer our services to their workers as a valuable employee benefit. Co-founded in 1996 by Nobel Prize-winning economist Bill Sharpe, Financial Engines currently offers personalized advice for saving, investing and living in retirement to millions of workers nationwide. Our strong ties with employers give us a unique opportunity to form direct relationships with their employees. Some people love the challenge of investing. Others prefer to focus their time elsewhere, but everyone needs to plan for retirement. Whatever their interest level in investing, Financial Engines combines cutting-edge technology and a personal, human touch to help all types of investors reach their retirement goals. For more information, visit www.financialengines.com.
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