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Why Social Media Archiving is a Must Have for Financial Services

Ever since social media first came into our lives with the emergence of platforms like MySpace in the early 2000s, it has shown no signs of slowing down. Today, over 30% of the world’s population utilizes some type of online community. In the U.S, that number amounts to 73%. Facebook itself has more active users than China’s entire population of 1.40 billion! While social media offers the benefits of extended reach, flexibility and freedom as a means of communication, financial services firms can find themselves at serious risk if they fail to archive social media content like other business communications. 

Why social media archiving is a must-have for financial services

Organizations across industries have jumped on the opportunity to use social media as a tool for branding, customer service, and sales –  with a projection that digital sales could account for more than 40% of new inflow revenue within the next 5 years. One industry experiencing particularly high returns on the investment in social media is the financial services industry, with year-to-year growth averaging 31%. In a recent survey, 79% of Financial Advisors said they had successfully acquired new clients through social media.

While social media offers the benefits of extended reach, flexibility and freedom as a means of communication, financial services firms can find themselves at serious risk if they fail to treat social media like other business communications, equally subject to regulatory laws by FINRA, SEC and FDA, including but not limited to:

Rule 17a-3 and Rule 17-a4

In a recent regulatory notice concerning blogs and social networking sites, FINRA stated that firms must retain records of all business-related electronic communications to remain compliant with Rule 17a-3 and Rule 17a-4 under the Securities Exchange Act of 1934 and NASD.

Rule 17a-4(b)

The SEC issued a rule that requires firms to keep records for business communications made via social media, even if only distributed internally. It also stated that broker-dealers must preserve records for a period of not less than three years, with the first two in an easily accessible place.

Rule 4511

This law requires organizations to preserve records under FINRA and SEA rules, in a format that complies with SEA rule 17-a. It also requires record preservation for 6 years

Regulatory Notice 10-6 and 1139

These laws focus on issues relating to FINRA members’ use of social media, including record-keeping, supervision and responding to third-party posts and links.

Failure to comply with these regulations can result in hefty fines, bad publicity, and ultimately loss of business. In April 2015, WealthForge, LLC was fined $20,000 for failure to use an  adequate supervisory system that captured, reviewed and retained social media communications used by its representatives.

Later in the year, Scottrade Inc was fined an astonishing $2.6 million for failing to implement a supervisory system or retain securities-related electronic records in the required format stated by the rules.

While there are a few options for collecting the required records for compliance, social media archiving is the most relevant technology solution that automatically monitors specified social media feeds and archives all activity associated with that feed. It also provides authentication, so that the record can be verified. Financial Services firms are in dire need of social media archiving technology; and as new rules continue to come into play in the future, they simply cannot afford a delay.


PageFreezer is a leader in the online archiving industry. We’ve been developing our state-of-the-art cloud-based system since 2010, helping over 500 clients including financial firms, multinationals, and government agencies meet their compliance requirements. We know the rules inside and out, and have the technology and systems for easy, simple, affordable social media compliance.

Archiving for FINRA Social Media Compliance

Financial firms are naturally cautious when it comes to new communication technology. After all, they understand that regardless of the medium the general rule applies; they are accountable for all business communications. Plus, each new communication channel comes with its specific compliance issues that need to be figured out BEFORE any actual use.wall-street2However, social media isn’t new anymore. FINRA has created specific guidelines all the way back in 2010 (Regulatory Notice 10-06) and in 2011 (Regulatory Notice 11-39). That means, with a proper social media policy in place, financial firms just need to follow the guidelines and can Tweet and Post just like everyone else.Of course, a bit of discretion is involved. While a certain post coming from an individual might seem innocuous, coming from an investment advisor, can mean an entirely different thing. “SELL when you can” coming from a buddy referring to football fantasy, would mean something quite different coming from a broker.A good social media policy can take care of a lot of this. Separation of accounts, specific guidelines to who can say what, and specific approvals for different accounts can help ensure what goes out is vetted properly.Controlling what goes out is only half the battle. The other significant aspect is keeping accurate records of all business communications; who said what, when.
1. Recordkeeping The obligations of a firm to keep records of communications made through social media depend on whether the content of the communication constitutes a business communication.Rule 17a-4(b) under the Securities Exchange Act of 1934 (SEA) requires broker-dealers to preserve certain records for a period of not less than three years, the first two in an easily accessible place.Among these records, pursuant to SEA Rule 17a-4(b)(4), are “[o]riginals of all communications received and copies of all communications sent (and any approvals thereof) by the member, broker or dealer (including inter-office memoranda and communications) relating to its business as such, including all communications which are subject to rules of a self-regulatory organization of which the member, broker or dealer is a member regarding communications with the public.”The SEC has stated that the content of an electronic communication determines whether it must be preserved.

How to record social media communications

Even for a technically sophisticated user, social media record keeping seems onerous. Sending out a Tweet is one thing, now you’re supposed to record it? For three years?This sounds like a job for Superman social media archiving. Social media archiving is a technology solution that automatically monitors specified social media feeds and archives all the activity associated with that feed. It also provides authentication, so that the record can be verified.PageFreezer Software has been providing this service since 2010 to hundreds of financial firms. We know the rules, inside and out, and have the technology and systems for easy, simple, affordable FINRA social media compliance. Using the same dashboard, you can also archive all your website and blog content.Visit our Financial Services Compliance page to learn more.

Archiving for FCA Social Media Compliance

In March 2015, the FCA (the UK Financial watchdog, The Financial Conduct Authority) issued compliance guidance for how financial firms can use social media:FG15/4: Social media and customer communications: The FCA’s supervisory approach to financial promotions in social mediaThe_City_London2It’s twenty pages long so, as with any government financial document, chock full of specific details. Obviously, if you’re in the industry, you (or probably your compliance officer) should absorb it all. Today though, we’re just going to focus on the archiving part; the requirement to keep accurate records of who said what, when.Section 1.25 cuts to the heart of the matter:
Firms should also keep adequate records of any significant communications. As well as helping to protect consumers, these records enable the firm to deal effectively with any subsequent claims or complaints. Firms should not rely on digital media channels to maintain records, as they will not have control over this: social media in particular may refresh content from time to time, with the consequent deletion of older material.
In other words, use an archiving service. While you might see that as a self-serving statement, it’s none the less true. Social media archiving services have the processes, technology and knowledge to ensure you have these records in place (without the need to develop everything in house).Financial Communications – Promotional or non-promotional?In general, when using social media financial firms will have two types of communication; promotional and non-promotional. As the non-promotional communications do not involve a financial aspect it’s a non-regulated activity and do not require archiving.However, anything that even has a hint of financial promotion probably falls under the regulations and thus needs archiving. Anything that “includes an invitation or inducement to engage in financial activity” is considered promotional. Be careful, a few words can turn an otherwise non-regulated communication into something that now falls under compliance.Personal, or in the course of business?Another factor is ‘in the course of business’. Are you communicating as a person, with your personal views? Or, are you communicating for business? Ensure there’s clarity, so that no one can mistake one for the other.Just because it’s a “new” medium doesn’t mean that the old rules don’t apply. All the previous rules for factors such as misleading statements, clarity, and fairness are still in place. You need to consider the medium and the intended audience; disclaimers, emphasis and balance all need to be taken into account.The guidelines go through many examples, showing what is compliant and what is non-compliant. By understanding these examples, and having proper internal policies and procedures in place, UK financial firms don’t have to be afraid of social media. Just make sure everything (including proper social media archiving) is in place BEFORE you start Tweeting and Posting!

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Online Records Retention

5 Tips For Online Records Retention

How is your business dealing with the issue of digital record-keeping and online document security? Do you feel confident that you could present your records as authentic evidence to a regulator or judge? How quickly could you locate and obtain particular records or web pages if you were asked to produce them? These are the hard questions that smart businesses will ask themselves in the midst of rapidly changing digital world. Financial companies, publicly traded companies, and even governments must recognize the need for retention solutions that are up-to-speed with today’s new technologies (also the new regulations and demands that accompany them.) If your online back-up plan needs an overhaul, keep these points in mind during the remodeling.

1. Fragmention is not your friend.

Document management and compliance experts say when it comes to digital records, companies can get bogged down in narrow issues rather than looking at the big picture. Backup systems, software options, and other management solutions can be distracting from a focus on the overall flow and efficiency of the company. Here’s the deal: you’ve got lots of online content. It all needs to be preserved impeccably if you’re to remain both compliant (to records laws) and prepared (for legal situations).  PageFreezer speaks to that comprehensive approach by providing regular and secure archiving of all your online activity — as much or as little as you specify. No fragmentation — just seamless, automatic preservation of your records.

2. Regulation compliance may not be enough.

While it’s nice to know you’re in line with SOX, SEC, or FINRA requirements, bear in mind that the risk of litigation against your company is a pressing issue that must be addressed.  Many companies mistakenly believe that being in compliance with records retention laws automatically means their records won’t be challenged in court. Not so! As noted by Financial Advisor Magazine in an article on the subject, courts are increasingly questioning the validity of digital records.

A stunning example of this is the 2005 case of Vee Vinhee vs. American Express Travel Related Services Company Inc. — in which Vinhee (who was filing bankruptcy while owing over $40,000 to AmEx) won his case without legal representation and without even attending the trial. Amex lost because the company rested its case on its internal computer records, which could not be proven authentic to the satisfaction of the court.

3. You have the burden of proof.

The example above highlights the fact that companies are being held responsible for proving the authenticity of their records. The court must be convinced of the fact that the records have not been tampered with. According to Judge Christopher Klein (in his comments on the Vinhee case), the key issue is that the record is what it purports to be.  Is your business prepared to shoulder the burden of proof in court? It’s not such a burden when you utilize PageFreezer — we put a digital signature and timestamp on every page to assure data integrity and authenticity. Plus, we employ powerful search features that help you find the exact records you need, when you need them.

4. Better safe than sorry.

Another case concerning the admissibility of online records was that of Lorraine vs. Markel American Insurance Company (dated May 4, 2007).  This suit dealt with lightening damage to a yacht that was owned by Jack Lorraine and insured by Marckel. Both sides presented e-mail evidence to support their claims, but the submissions were rejected by Chief U. S. Magistrate Judge Paul W. Grimm. He said they failed to meet the FRE standards for admissible evidence. It was a landmark ruling in the arena of digital evidence. Grimm noted in his statement about the ruling, if it is critical to the success of your case to admit into evidence computer-stored records, it would be prudent to plan to authenticate the records by the most rigorous standards that may be applied. In other words, better safe than sorry! Choose the safe route — PageFreezer preserves your archives according to the highest standards possible.

5. Delegate — and breathe easier.

The whole issue of online records retention can be a real headache in today’s ever-changing technological climate. Companies drive themselves crazy trying to stay on top of the regulations and requirements! Don’t underestimate the peace of mind that comes with delegating this matter to a reliable outside service like PageFreezer. We handle the technology and shoulder the responsibility of maintaining perfect records for your business because you have other things to do. Feel free to do them while we archive your websites — keeping your company informed, compliant, and prepared.

Financial companies & social media

How financial companies are succeeding at social media

The past couple of years seemed to bring more fear than fun for the financial industry in the social media arena. There was the much-talked-about ‘SEC sweep’ last year, in which investment advisors were asked to provide extensive information about their use of social media.  There were the stringent guidelines posted by Massachusetts for advisors within the commonwealth, stressing record keeping, monitoring, and periodic review of social media use.  And early this year, there was the SEC ‘risk alert’ on the use of social media by advisors, which emphasized the importance of compliance policies including record-keeping and third-party content.  All in all, financial service providers seemed caught between the risks and rewards of using social media — and not many companies were interested in testing the waters to see how regulators would respond to gray areas.

But some in the financial sector refused to back down, pushing the SEC and FINRA to provide guidance that would recognize the importance of social media as an efficient and effective communication avenue for the industry.  A victory came when FINRA backed away from a proposal that would have required broker-dealers to file social media postings with the regulator.  Such a requirement would have placed excessive strain on firms and FINRA alike.  Instead, the current guidelines stress oversight and monitoring as the keys to responsible social media activity by advisors.

Let the tweeting begin

Several financial services providers are leading the way into the social media fray, showing the rest of the industry that it CAN be done, and done well.  The finance sector is “social” by its very nature.  Connecting with clients/customers, advancing into new markets, providing timely advice, and increasing customer service are key motivators for the industry to move into social media.  Here are a few ways financial companies are making it work.

The human touch

Back in January, Wedbush Securities, a leading financial services provider with 1,000 employees across 100 offices, gave the social media green light throughout the company.  From advisors to bankers and everyone in between, Wedbush personnel were given permission to engage online with prospects and clients (within compliance-friendly parameters, of course).

For Wedbush, the main incentives to pursue social media were humanization of financial services and connection with the market.  “We want our team to be truly ‘social’ with their networking,” said Natalie Taylor, Vice President of Marketing, Wedbush Securities, in a news release.  “By offering a more organic approach, their personalities will show and allow them to truly connect with people.”  Like other businesses, Wedbush plans to use social media to add the human touch to an industry that often comes across as impersonal.  They manage the risks by training employees on the appropriate usage of social media in a financial context, and offering guidelines through a social media policy.

Making finances fun

To be honest, no one really equates the finance industry with excitement or pizazz.  But social media is an avenue that can make financial services more interesting.  Several companies have creatively used social media to boost their brand — like Geico, the insurance company who linked mobile and social technologies to their memorable marketing campaigns.  They developed an iPhone app (and similar Facebook app) called BroStache (as a nod to their humorous commercial about smartphones) with which users can see how they would look with a mustache.  As a result, more folks than ever before have Geico’s tagline (15 minutes could save you 15% or more on car insurance!) stuck in their heads.

Another snappy idea came from Capital One, the bank who partnered with Zynga to integrate Facebook marketing with popular social games like Cityville and Farmville.  Players on Cityville could open a Capital One branch in their city, while players on Farmville could acquire a limited-edition Capital One goat.  “The explosion of social gaming offers a great way to engage consumers with our brand,” said Jack Forestell, executive vice president of Digital Strategy at Capital One.  Sure enough, the promotion garnered attention for the bank’s brand and pushed lots of extra traffic to the Capital One Facebook page.

Getting the word out

Investment advisors face particular regulatory challenges with social media.  But they need not be silent in order to maintain compliance.  The website of Bill Gunderson, president of Gunderson Capital Management, Inc., sports a trendy-tech feel and is veritably plastered with social media (Facebook, Twitter, and his self-created stock-tracking apps for iPhone and Android).  Gunderson’s confidence in the social media space generates a feeling of trust and rapport with much of his target audience — people who are using their smartphones for business communications every day.  As an investment advisor registered with the SEC, Gunderson is subject to industry regulation but manages risk by focusing on the distribution of advice, rather than blatant marketing or self-adulation.

Connecting with customers

If you want to deliver stellar customer service, you should communicate with your customers through avenues they are already using.  Nearly everyone is plugged into a social network of some kind . . . and that’s why Ally Bank was recently lauded as a leader in the social media space among financial institutions.  Their customer-centric business model focuses on providing clear, helpful information through Twitter, Facebook, YouTube, and Ally’s Straight Talk blog.  “Social media allows Ally Bank to connect with customers in a straightforward way, in forums that make it easy for them to access information,” said Sanjay Gupta, chief marketing officer of Ally Financial.  The bank is “user-friendly” — utilizing social networks to integrate finances with the other aspects of everyday life.

Minding compliance policies

There’s no denying that the finance industry faces complex regulatory issues.  No company should embark on social media without clear policies regarding record-keeping, oversight, and other applicable rules.  But financial service providers CAN join the industry conversation.  Just make sure you have the right tools to track, archive, and locate your social media activity in a way that’s acceptable to regulators.  And check out our advice on properly archiving web and social media for financial services. Then, get going! Your customers are just waiting to have a conversation with you.

Social Media Archiving Needs

Social Media Archiving: What do you REALLY need?

While many industries have dived into social media with abandon to reap the benefits of free mass communication, financial firms have been forced to take a more cautious approach.  The heavily regulated financial industry has looked for guidance from FINRA concerning recordkeeping and approval policies, and there’s been a lot of talk about how social media’s landscape-shifting nature might change compliance rules for the industry.

Fortunately, FINRA has been very helpful in defining its expectations, most recently at the regulator’s annual Advertising Regulation Conference.  From an archiving perspective, this list reinforces the idea that firms should implement strong retention policies for social media.  Nearly everything must be captured to remain compliant.  Here are some guidelines based on FINRA’s indications at the conference:

  • Both static and interactive web content must be archived.  Financial firms have been advised to consider whether their content is static or interactive.  Static content consists of pre-planned communications (such as traditional website ads) that can’t be altered, commented on, or quickly re-posted.  Interactive content consists of spontaneous communications (such as Twitter or LinkedIn posts) that are open to comments or dialogue.  Though static content must be pre-approved by FINRA to remain compliant, BOTH types of communications must be archived.
  • Third-party comments to firm-authored posts must be archived. To what extent is a firm held responsible for third-party comments or posts on social media platforms?  FINRA has advised that since a firm can’t control what is posted in a dialogue on Facebook, Twitter, or similar online community, a firm is not held officially responsible for such interactive content.  However, these comments and posts must all be captured to remain in compliance with recordkeeping requirements.
  • The critical feature of any social media compliance solution is archiving. The ability to archive content (and reproduce it in a timely manner to a regulator) is the most important feature of any solution for social media compliance.  Although some firms may look for pre-approval features to aid the following of internal approval policies, FINRA has made it clear that the single indispensable requirement is that social media content be captured and stored unaltered.  Make sure your archives can be re-played if your posts contain rich media like audio or video.

In summary, the keys to compliance are clearly defined social media policies, the implementation of such policies, and an emphasis on record-keeping and retention of social media content.  When regulators come knocking, financial firms should be prepared to demonstrate an archiving solution for their social media content that fully meets regulatory requirements.

Now that firms are clear on what FINRA expects, the new year can bring new freedoms in social media ventures… as long as the essential steps are taken to remain compliant.

For more information please visit our social media archiving page.

Social media mistakes

Is your company making the worst social media mistake?

social-logos-glow

We know.  Social media has grown so quickly, been adopted so widely and become so universally recognized as a viable means of online communication for businesses . . . it has left your company’s proverbial head spinning.  Keeping a lid on employees’ personal usage of social media at work is hard enough.  And now, across industries, organizations are creating their own social media presence, often without a clear idea of how to balance risks and rewards.  How were you supposed to keep up with it all?

Hopefully, you have thus far avoided the major pitfalls that can come with adopting social media as an organization — embarrassing PR gaffes, compliance issues, or legal tussles — but is your company committing the worst social media blunder of all?  To avoid this one supreme mistake is to avoid dozens of other potential disasters.

It is the mistake of embarking on social media as a company — without a social media policy.  No clear guidance for personnel on how to engage with the public on behalf of the company, or how to maintain their personal social media activity in a way that upholds the company image.  No outline of the legal do’s and don’ts; no suggestions for creating worthwhile content.  And a staggering 76% of companies make this mistake, according to a recent study.

We understand that many organizations have been taken unawares by the social media storm.  But investing time in developing a good social media policy will pay great dividends by allowing your online communications to flourish without the worry of legal or public relations disasters.  A social media policy doesn’t have to be complicated.  Certain industries will have more to cover than others, but in general you simply need to outline that social media content from your company should remain respectful, honest, law-abiding, and relevant.

Make it easy on yourself by downloading one of these Social Media Policy templates — a variety of examples to choose from — and tailor it to fit the needs of your organization.  Also, check out these helpful tips on developing a good social media policy.  There’s no reason to proceed any further in your social media journey without the security of a policy to keep everything legit.  It won’t solve all your problems, but it will prevent a good many of them!

Don’t forget that in addition to your policy which directs the use of social media within the organization, you will also need to have a plan for preserving your social media records since they are part of your business records.  Copies of your social media activity may be requested for litigation or regulatory purposes, especially if you are in the financial, pharma, government, or legal industry!  But we’ve talked about that elsewhere.

Prevent problems with social media usage before they start.  Develop a social media policy that’s simple and clear, allowing your personnel the freedom to represent your company online within parameters that will keep everyone in the conversation . . . and out of trouble.

PageFreezer tops “Archival Acid Test”

Web archiving continues to be a critical issue as companies and organizations search for the most foolproof methods of preserving their online content. There are numerous tools and services out there, but how can you be sure which one can stand up to its claims? The primary concern is that an archived page with complex content can be very hard to capture and replay perfectly.

To investigate the strengths and weaknesses of various archiving tools, the Web Science and Digital Libraries Research Group at Old Dominion University developed an “Archival Acid Test”. The test evaluates features which modern browsers execute well, but preservation tools often have trouble handling (such as Javascript, CSS, and HTML5 content). The researchers tested five web archiving services – Archive.org, Archive.is, Mummify.it (no longer functional), Perma.cc, and WebCite – along with the archiving tools Heritrix, WARCreate, and GNU Wget. The findings were published by the University in a paper, which revealed that none of the tools tested were able to fully render a captured version of the elements that displayed perfectly in a live web browser (such as Chrome).

Since PageFreezer is industry-leading in its ability to capture and replay web content, we asked the group to put our service to the test. The results were telling – PageFreezer was the only tool to pass every requirement, even advanced features!

PageFreezer archiving acid test graphWhen you are using PageFreezer, you can be confident that you are working with the most advanced website archiving solution available. It makes PageFreezer a smart choice for regulatory compliance and other cases where accuracy and completeness are critical.

Archives on Demand

At PageFreezer, we believe in making website archiving easy. Really easy. That’s why we developed a user interface that puts you in charge. You can manage, edit, and fine-tune your archives without having to contact customer service or put in a request. The power is yours!

We even made it possible for you to create an instant archive of your website (or social media page) anytime you choose. This handy-dandy feature puts you in control and allows you to…

  • Save storage space. If your website doesn’t change frequently, you may choose to capture it only once per day or week. This helps you save storage space (and money). With archiving-on-demand available, you don’t have to worry about altering your archiving schedule if sudden changes are made to your site. Just take an instant snapshot and you’re good to go.

  • Be prepared for anything. Many companies archive their sites for litigation protection or regulatory compliance. If you suddenly need to produce a current copy of your website, you can do so easily, with no wait time.

  • Confidently update your website. Suppose you are working on an entirely new website, or doing a major overhaul of the one you have. You can feel confident about changing content when an instant archive is always available. This also goes for temporary pages or when you need to delete comments off your blog or social media page. No need to wait for the next regularly scheduled capture — just archive instantly and proceed with confidence!

On-demand archiving is simple to use. Here’s the breakdown:

  1. Log into your PageFreezer account

  2. Find the website you wish to capture and click “edit” on the right

  3. At the bottom of the Settings page, click “Advanced”

  4. That little button that says ARCHIVE NOW — click it!

Ta-da! Instant archive. You get a fully functional copy of your site as it exists right now, that stands as admissible evidence in court. Plus, you get that peaceful feeling that you have covered your bases before making changes to your site. And it happened with a few simple clicks. Now that was easy!

Global Forex Broker chooses PageFreezer

An award-winning global provider of foreign exchange (forex) trading services, one of the largest in the industry, has selected PageFreezer as their solution to archive company websites for regulatory compliance and litigation preparedness. This will include the archiving of online discussion forums, Facebook pages, LinkedIn and Twitter accounts. Listed on the NYSE since 2010, the firm strives to maintain transparent and compliant business practices.

PageFreezer’s services will assist them in preserving a careful record of the corporate web presence, with archives that stand as non-refutable digital evidence in court.

As a vocal advocate of foreign exchange regulation and increased investor protection, our new client is one of the first forex firms to register as a Futures Commission Merchant (FCM) following the passage of the Commodity Modernization Act in December 2000.  As such, the company is subject to strict financial standards and oversight by regulators.  PageFreezer’s archiving of websites and social media will allow the company to maintain complete, searchable, admissible records of their online activity, making it simple to quickly provide regulators or legal counsel with requested information.

Online records retention has become a pressing matter for the financial industry, especially within the U.S. regulatory framework, widely regarded as one of the best in the world for investor protection.  Stringent retention requirements imposed by the FINRA, SEC, and other regulators, combined with increasing amounts of online communication and marketing, has caused many companies to search for robust archiving solutions for their Internet content.  Lawsuits and investigations, common in the financial industry, can be resolved more quickly and smoothly for companies that keep careful records of all online activity, including social media and discussion forums.

PageFreezer’s industry-leading archiving solutions have already provided a number of financial organizations with the peace of mind that their electronic records are being backed up automatically, in compliance with regulations.  We are confident that our new client will benefit from the worry-free archiving of their online presence, and pleased that they have chosen PageFreezer to provide this service.