for social media
and website communications. Additional
guidance for social media and website communications has issued from the Securities and Exchange Commission (SEC), the
Federal Trade Commission (FTC), the National Labor Relations
Board (NLRB) and the Federal Trade Commission. (The FTC has
a good online resource center for Advertising and Marketing that
includes a section for Online Advertising and Marketing: www.
Most recently, in April 2017, FINRA revisited this growing
online presence with Regulatory Notice 17-18, which may once
again influence “best practices” for the entire financial services
industry. It takes on more complicated issues that have evolved,
including the increasingly blurred lines between business and
personal communications, the explosion of text messaging as a
standard form of communication, the potential responsibility for
content via hyperlinks, and customer testimonials.
FINRA also provided an update on the prevalence of social
media ( www.finra.org/sites/default/files/notice_doc_file_ref/
Regulatory-Notice- 17-18.pdf). It cited an October
2015 study from the Pew Research Center, indicating that 65%
of adults use social networking sites as compared to 7%, just 10
years earlier. In April 2016, Facebook Messenger reported 900
million monthly active users, and WeChat reported in March
2016 that it had added nearly 200 million monthly active users
in the previous year.
It seems as if social media changes at the speed of light. Every
time policies and procedures are set, technology advances and
it is time to review the plan again. While every review is different, and guidance may change and evolve, the following“how to”
guide should be helpful for updating your social media policies.
Step One: Take Inventory
It is no easy task to take inventory of your institution’s social media
channels and website footprint. Social media involves more than
just your marketing department promoting or advertising products
or services. It can be very granular, at the branch level, through