Is your firm planning to expand its base of investor prospects?  Have you formalized your business development plans?  Do they include Twitter?  It the answer is "no" to this last question read on…

Twitter is a communications platform which your firm can (and should) utilize to distribute investor oriented content, provide news on your firm, communicate the requisite details for webinars and events.  Even if you look beyond the interactive nature of this social network and focus only on its transmission capabilities, it is a tool that cannot be overlooked.  Beyond the fact that it can greatly extend your message reach, build awareness and increase traffic to your website… it is free.

Getting Started Is Easy

Simply go to www.Twitter.com, establish your account, choose your username, preferably one that focuses on your business name and or service offering.   Once you've set up your account you’re ready to establish your profile and bio to aide others in finding you when they conduct a search.  These profiles are considered "static" content and should be pre-reviewed by your compliance partner for FINRA compliance.  Now it is time to determine who you would like to “follow.”  Twitter’s search function makes it easy to search by individual, firm name or subject matter.  When you find people you’re interested in following, simply click follow next to each of their names.  In short order, several of these people will decide whether or not they would like to follow you back, building your list of “followers.”  

So now that you know how to use Twitter, let’s review some of the basic information that you will need to maintain your compliance with FINRA’s rules and regulations.  Of note FINRA helped provide clarity around social media website and blog usage this January when they issued rule 10-06.  

 
Compliance Basics

Twitter is a publicly available website (no password required) and is therefore considered by FINRA to be an “advertisement.”  The act of Tweeting is considered to be a “public appearance.”  Of note, your firm in conjunction with your compliance partner will need to establish a policy for usage by your employees and a process for both pre-review (i.e. investor oriented content to be distributed, profiles, bio’s) and periodic scanning on a real-time or post-review basis to insure compliance.

FINRA rule 10-06 recognizes that it is beyond the reach of your firm to control and or even to monitor all communication on the various social networks and as a result acknowledges the fact that 3rd party posts are generally not attributable to your firm’s communications.  Unless that is your firm was involved in producing, approving or endorsing the content.  Hence, 3rd party posts can become attributable to the firm if they are republished, re-Tweeted or “favorited” on Twitter for example because they may then be considered an endorsement and therefore attributable to the firm.

FINRA requires that advertisements and public appearance related content be retained for a period of three years.  This includes advisor posts, status updates and or Tweets, whether sent from the office, home or elsewhere.  Thus these activities, in conjunction with any Twitter profile updates must be captured and maintained. 

Therefore, your firm will need to implement a social networking monitoring and archiving service.  There are a range of software or freeware solutions providers that serve the Broker-Dealer/ RIA market including; SMARSH which provides compliant e-mail archiving and social networking monitoring solutions.  Socialware which provides a range of social network access control, monitoring and archiving services and Arkovi which specializes in capturing and archiving Twitter streams at the adviser level. 
 

Conclusion

Twitter will afford your firm with the opportunity to access information more readily, share content more easily and drive traffic to your firm’s website more effectively.  So, if it is prospects that you’re looking for to support your firm’s business development effort, don’t overlook the obvious.