[Finance] An Entangled Financial Web: 3 Best Practices to Stay Compliant with your Online Communities
That’s precisely the issue vexing financial services providers regarding their online communities (both social media and support communities) today.
Regulation and the Specter of Adoption/Entanglement
Thanks to the Financial Industry Regulatory Authority’s (“FINRA”) Regulatory Notice 17–18 (along with Rule 2210 and a host of other SEC and FINRA rules), financial brands who are active on social media now have to worry about “adoption and entanglement”.
In short, any piece of content shared by a financial services provider is considered an “adoption” of said content, and thus, subject to all the regulatory scrutiny that accompanies any other piece of material produced by that company.
Banks are already used to running their in-house content through internal compliance to ensure everything is on the up-and-up. But to subject every piece of third-party (or user-generated) content to this additional – and often unwieldy – compliance process as well would be enough to snarl the community’s content machine to a near halt.
Sadly, there’s no way around the issue at present. Nevertheless, the following 3 best practices can help banks stay on the right side of financial law without hampering their ability to find and share valuable third-party content.
1. Choose Carefully
Only choose content from reputable third-party sources. It’s one thing to share a piece from CNN Money or even a financial guru like Dave Ramsey. It’s quite another to share a low-rent SEO post from some random financial adviser.
A further complication has to do with the presence of comments. Remember and beware: when you share a blog post, every last letter of content on the page is subject to the same adoption and entanglement rules.
And nobody wants to be on the hook for the errant comments of a half-witted internet troll.
That said, choose evergreen-quality posts that don’t allow comments. If you absolutely must share a post with active commenters, subscribe to the feed so you can run every new comment through compliance.
2. Develop a Process for 3rd Party Content
As I said above, having to run your content through the compliance mill is a drag. But with a streamlined process in place, your bank will avoid the bulk of the slowdown.
Work with your compliance department to develop a ‘fast-track’ for third-party content used in online community. Take it easy … this doesn’t mean compliance drops everything they’re doing each time your community manager sees something interesting on Twitter. It does, however, mean they must develop a way of consistently and efficiently evaluating third-party content for community use.
Of course, the success of this best practice will depend on the presence of the next…
3. Dedicate Compliance Resources to Community Management
When it comes to online marketing, community is the buzziest of all buzz words – and for good reason. Social media has shifted the way consumers live, move and have their being online. Community is no longer a clever marketing trick; it’s a necessity.
Let me be clear: if your bank isn’t developing a band of loyal customers and using them to connect with future business, you’ll be extinct by 2020. Therefore, serious decisions must be made to allocate the appropriate resources (time, talent and budgetary treasure) to making online community a reality.
That means freeing up and dedicating compliance resources to ensure your community managers have the access they need to curate and share a steady stream of valuable content with their community. You can put a process in place, but if you don’t hire the right manpower to execute that compliance process, you’ll inevitably hamstring your community.
Every financial provider knows how serious regulatory authority can be. The crushing weight of federal injunctions and fines can be enough to tank most financial institutions.
Don’t let that keep you from taking the next step in ensuring your continued and competitive existence in a digitally connected world. Talk with your lawyers, gear up your compliance department and get ready to make a concerted effort at developing content-driven community this year.