Are Pre-approved Social Media Posts Necessary?

Pre-approval of all social media content before posting was the norm a few years ago, when firms were first taking baby steps in using social media. After a rep created content, it would go into the compliance department’s queue for review and approval before posting. This was viewed as a way to stay compliant with regulations as firms figured out how to responsibly begin using social networks like Facebook, LinkedIn and Twitter. Social media guidance from regulators wasn’t completely defined yet either, making the situation more complex.

Fast forward to today, and the industry is moving away from the pre-approval of most social media content toward post-review. Here’s why:

Social media is a two-way conversation. To reach customers, you must shed the habit of talking at prospects, and engage with them instead. If you’re at an event and another attendee asks you, “What do you do for a living?” you wouldn’t want to reply, “Let me get back to you…I need to check with compliance first.” The person would move on to talk with someone else, possibly building an immediate rapport and working relationship. Pre-approved interactive conversations don’t work well in the real world, and they don’t work well on social media, either.

Authenticity and connection are key. Content that’s developed and edited to death can come across as canned and impersonal. Also, if content is created by someone who isn’t close to the customer, it can lead to a less-than optimal customer experience—by making it harder for reps to quickly and intelligently anticipate client needs, answer questions, and offer timely solutions. Genuine two-way conversation is the best way to build relationships online and offline.

Time is money.  If you don’t move fast on social media, you lose opportunities to connect. Pre-approval of posts and comments slows down the connection process, or can halt it altogether. A firm with more than a few reps would never be able to keep up with pre-review of all their social posts and still be effective.

Social media is a dynamic, oftentimes real-time exchange of information. To use it most effectively, ditch the pre-review and take a proactive approach.

Prepare For Success.  Having defined social media policies gives reps the guidelines they need to be effective on social media, while staying compliant.  Social media training should include a review of your firm’s social media policy, social media best practices, critical do’s and don’ts to keep in mind, personal versus business use of social networks, and state how your firm will be monitoring and responding to infractions of policy violations . Armed with this training, reps are less likely to misstep on social media.

Risk-Based Supervision. Some social media content (static content that doesn’t change often, including profile information on Facebook, Twitter, and LinkedIn) still must be reviewed and approved by a broker-dealer before it can be posted. However, the SEC and FINRA don’t require pre-approval of dynamic social posts and comments; they just require that this type of social media content is supervised. Many firms have adopted risk-based supervisory procedures, and use technologies that support post-review of social content, including sampling, lexicon-based, and policy match methods.

Having a system for the monitoring (aka post-review) of social posts and comments allows your firm to identify non-compliant social media use, so you can quickly deal with the infraction and focus on growing your business, rather than becoming overwhelmed by a pre-review process. Why waste your time, energy and resources reviewing compliant posts, when you really just need to find and correct the posts that indicate real risk?

With appropriate policies and training of your reps on your firm’s social media, and armed with an effective supervision tool, the headache-inducing, inauthentic and business-harming slowness of pre-approved social posts can be a thing of the past.