When Morgan Stanley started down the social media path, we did so because of demand from our advisors. Eager to do the right thing from a compliance standpoint, our marketing group would frequently field advisors' requests for permission to connect with their clients on LinkedIn. After hearing this enough times, we dug into the issue to understand FINRA's stance on social media. It was January 2010 and Notice 10-06 had just been published. The guidance was that social media use was allowed, but all the same "communications with the public" rules applied. If firms could figure out a way to archive and supervise social activity, they could unlock the use of social media for advisors. While its a compliance problem, it requires a technology solution.
This may not be obvious to firms when they begin the process of creating a social media program. Firms need technology resources and budget allocation if they want to make this happen for their advisors.
Once a technology solution is in place to meet regulatory requirements, the legal and compliance teams then need to decide what the firm position is for each social website and each site's functionality. At MS, we reviewed each sites features on a big conference room screen. We wanted to understand how each site worked and to determine which, if any, function should be allowed, moderated, or blocked. It's a tedious process but one that technology vendors can assist with, especially for smaller firms. That began a tight working relationship between marketing, legal, compliance and the risk teams. Thats why the key to launching a social media program at your firm is to develop a cross-functional team, with frequent meetings.
Lastly, senior management needs to support and promote social media use by advisors. When senior executives believe that social media is a business tool, they will be more likely to provide the required technology and compliance resources. There are enough examples of success stories in the public domain to help make the case to senior management if advisors need proof points. At MS, we have close to 5,000 advisors using social media. Almost 30% of them say they have brought in at least one new client as a result of using social media. Firms today should treat social media just like the phone or email; it's a basic communication tool.
To get a social program up and running at your company, you need three things: technology solution, compliance focus, and senior management support. But it all starts with advisors speaking up about their desire to leverage social media for business.
Lauren Boyman leads the digital strategy for Morgan Stanley Wealth Management, the first major wirehouse to allow advisors to use social media in a compliant way. She is responsible for client web and mobile, as well as advisor mobile and social media programs. Follow her on Twitter, @LBoymanMS.
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