Category Archives: Social Media Compliance

Cool What?

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We recently had the honor of being named a GartnerCool Vendor in CRM Customer Service and Social.” All I’ve heard since then is, a bunch of questions and comments, like:

 

 

- Who’s Gartner?

- What does this mean?

- You’re really not that cool!

 

 

 

 

 

I’d like to clear this up for everyone, once and for all.

Who’s Gartner – they are the clear leader among IT Analyst Firms. To put it into perspective, they are a $1B+ organization whose ticker symbol is IT. Enough said. Specifically to us, they have been preaching for years to CIOs (Chief Information Officers) that IT needs to function as a strategic business unit, not as a group of tech people.

What does this mean? – It validates everything we’ve been doing. When I demo Engage121 I always hear prospective clients say “cool,” to which my response is always “Why?” Because nothing we do is actually cool for the sake of being cool. There is always a method to the madness; or as we call them at Engage121, Business Solutions…a.k.a.…the same thing that Gartner is challenging CIOs to deliver on a daily basis.

What are business solutions? It depends on your line of business. For Restaurants, you want more butts in seats. For Real Estate Organizations, you want more listings and more sold houses. For Financial Institutions, you want to retain and grow your client base. We help our clients achieve their specific objectives through social media every day. Heck, I challenge you to find a corporate objective that social can’t influence.

And to my friends who say I am really not that cool, you know who you are. You are just busting our chops, because you are right there with us. Together, we are in the midst of working on some stuff that is straight up revolutionary. We are changing the ways business is done on a day-to-day basis.

Things couldn’t be any more exciting at Engage121 than they are right now. I am thrilled that I get to enjoy the ride. For the rest of you, buckle up because big things are coming. How do I know? Because I’m cool.

 

Social Media Network Prospecting Is the New Cold Call

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“LinkedIn is like the gym, you get out of it what you put into it.” 

Editor’s note: A version of this article previously appeared at RecommendedAdvisor.com.

I use and connect through all available modes of communication, such as social networks like Linkedin, Twitter, and Facebook, and old traditional methods of face-to-face, the telephone, and email.  My goal is to use social media to connect with a prospect online, solidify the communication with a DM or email, and ultimately schedule a face-to-face chat for coffee.  I’ll even settle for a Skype conversation, Go-To-Meeting or a phone call.  The point is to understand what mode of communication your prospect prefers and adapt to their preference.  Like exercising at the gym, if you are going to put in the effort, make sure you are using the right equipment.

Social Prospecting Technique:
Depending on the success rate of the proactive medium, I adjust accordingly.  I like to start with LinkedIn by narrowing my search through “keywords,” then filter down by geographic region.  (You can also search keywords and geography on Twitter and Facebook.)  For example, if I am looking for people involved in healthcare services and social or digital media, I search for “healthcare and digital,” or “healthcare and social.”  If my goal is to set up a face-to-face meeting, I then narrow it down to Boston, Connecticut, or New York.  Fifty LinkedIn messages will result in 3 to 5 face-to-face meetings, or at the very least, 5 to 8 phone conversations.  I prefer to meet people in person.  Follow up is crucial. If you don’t keep track of who you have contacted, who has connected you, who has connected and hasn’t responded, you will get lost and eventually give up.  After my first message wave, I track who responded and who didn’t respond and place those messages in appropriately labeled folders, such as “Sent Email,” “Sent Invite,” “Answered Email,” “Meeting,” etc. so I can follow up with a second wave of messages.

I am not trying to recreate the phonebook online.  I don’t want meaningless connections in my LinkedIn network, or any network for that matter; I want my network to be strong and powerful.

Before I send my invitation to connect, I do a very brief search of their online history to discover a commonality we may share. If they have their own website, I can compliment them on it.  If they commented on a blog or Facebook post, I will also go and comment on it.  The connection clues are everywhere.  Talk about them and their interests to start the conversation.  They are online for a reason—figure out that reason and help them accomplish what they are trying to accomplish, and you will forever be connected.

If I am really interested in the prospect above the others on the search list, I also send a Twitter message and look at their Linkedin message (I may expand this to Facebook, Pinterest, Quora and other networks).  I find the cross-platform method increases my contact rate by 50%.

 

Twitter message response from a LinkedIn, Twitter convo:


 

 

Newly discovered friend admiring the cross-platform strategy:

 

 

 

 

Proactive Twitter reach-out based on my online profile and presence:

 

 

 

Twitter, Linkedin combo message response after connecting for a follow-up phone call:

Twitter:

 

 

 

Linkedin:

 

 

 

 

 

 

 

 

 

 

I discover what they are doing, what their challenges and struggles are, and then I am able to form a basis for my value proposition when they ask me what I do.  What a coincidence—I work with many companies that were in your same exact situation, and I helped them leverage social technology to…you get the idea.

My main goal is to have people come seek me directly for solutions to their problems.  This is my utopia.  This is like for many salesmen and women who have a prospect purchase their solution without even seeing a demo.  A recent prospect came to me via a LinkedIn group message response that wasn’t even directed to him, I didn’t even know he existed.  He found me and read my profile. My profile provided enough clues about a solution to prompt a meeting.  Everyone is watching on Social.

 

Proactive message to me based on a response I gave in a LinkedIn group:

 

 

 

 

 

 

Follow-up meeting with the gentleman he is consulting for:

 

 

 

 

 

 

 

Social networking allows me to leverage my message and get myself out there. What I do with the new opportunities is totally up to me and my tenacity to stay organized and follow up!

In the Healthcare or Finance Industry?  Worried about Compliance Controls?  From archiving capabilities, to HIPPA and FINRA keyword controls, Engage121 enables compliant social media for sales professionals in regulated industries. Inquire within.

- Rich LoPresti, Account Director Engage121

 

Audit Risk: Review Sites and the Consumer Financial Protection Bureau

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Financial institutions have a new reason to pay serious attention to online rating and review sites, according to a small article with big impact in the Monday, November 7th edition of Wall Street Journal.*

According to WSJ:  “The [audit] manual also encourages its auditors to consider complains lodged not only with the [Consumer Financial Protection] Bureau, but with such political actors as state attorney Generals and “on-line consumer complaint boards such as http://www.ripoffreport.com and http://www.complaints.com.” [Emphasis added.]

The Consumer Financial Protection Bureau (CFPB) was created with regulatory authority that far exceeds current financial industry regulations.  Banks have long endured regulatory audits for possible “unfair” or “deceptive” practices when conducting business with consumers. However, the CFPB has the newly expanded authority, granted by the 2010 Dodd-Frank Law, to look for “abusive” acts.

The first concern for banks is that the definition of “abusive” remains unclear.  The second and larger concern for banks is the CFPB can source online rating and review sites for evidence of possible abusive acts.  The article mentions two review sites as examples: RipOffReport.com and Complaints.com.  Engage121 monitors these two among the top forty consumer rating and review sites.  

Evidence of this expanded authority was first published (buried) in mid-October in an 802 page tome called “Supervision and Examination Manual – Version 1.0”.

Last Wednesday, the brawn of CFPB’s expanded authority came to light when the new head of the Bureau, Mr. Raj Date, addressed Congress.  Mr. Date described how the CFPB is empowered to “focus on the consumer” when regulating the nation’s financial institutions.

Engage121 is a social media management application that monitors all the consumer review sites that impact financial institutions, plus twenty social platforms and blog publishing tools, all in one integrated interface.  The Engage121 application allows our financial clients—ranging from large insurance and financial planning companies to regional and community banks—to engage consumers while maintaining compliance with regulatory institutions including FINRA and the SEC.

For more information or guidance on monitoring social media platforms and review sites for financial institutions, please contact Jack Serpa, executive vice president of Engage121, at 203-849-7246, jserpa@engage121.com, or @jackserpa.

* The WSJ article: http://online.wsj.com/article/SB10001424052970203716204577013804002477724.html?

Why should a bank use social media?

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Engage121, Inc. will be a sponsor at the New England Financial Marketing Association (NEFMA) fall conference in Newport 10/6 – 10/7.  Engage121′s Steve Paster will be there, and he offers his thoughts below on how banks can use social media to drive business goals.

As I am preparing for my trip, I keep thinking about the question I expect to get the most: Why should a bank use social media?

My answer is straightforward but hard to accept: You should figure out your marketing goals and objectives, and determine how to leverage social media to achieve them. 

Here are some examples of how this can be done:

  • Differentiation:  One bank’s money is as green as the other, yes?  Well, how about differentiating the consumer’s experience with social media?  We have financial services clients who are creating vibrant Facebook communities – and seeing dramatic increases in fans translating to new accounts, retention and overall awareness.
  • Product Awareness:  Our financial services customers want greater product awareness.  Personally, I use about 10 different companies for my checking, savings, retirement, insurance, credit card, mortgage, and car loan.  I am sure there is an overlap of services among those companies, and each would love to have more of my business (I just took diversification too literally I guess).  These customers can get the word out through social.
  • Customer Growth and Retention:  Our clients monitor what their clients and prospects are saying in social media.  They can identify trends and join the conversation, in real time, where appropriate.  Other community banks realize that they have something in common with their clients, their community, and use social media to show support, promote upcoming events, and show their active community stance.  This helps drive new customers and keep the ones they have.

As for me, I don’t “like” my bank on Facebook.  Why?  They don’t even have a page!  In general, my personal sentiment towards them would be neutral.  That is, until I recently learned that they plan to charge a $5 monthly fee if I use my debit card.  There is outrage against them on Facebook and Twitter, yet they do little to protect themselves or insulate their brand. 

If a bank has an engagement application in place, now would be the time to interact with the upset customers of my bank, and entice them to try a better alternative.  

Banks also worry about compliance (maybe that is why my bank does not have a page). Engage121 can help with that as our product has built in approvals, permissions and archiving that let banks comply. 

I am looking forward to talking to NEFMA attendees about meeting their goals compliantly through social media.

 



Adapting to the New FINRA Updates

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The Financial Industry Regulatory Authority (FINRA) updated their guidelines on how brokers may use social media.  Financial Advisor gives a comprehensive list of the top updates here.  Here are some of the highlights from that list as well as how we are helping clients meet these challenges:

Approval and Permissions

Engage121 has easy-to-use approval and permission features that allow a centralized way to review and approve content before posting which will be crucial, given the following new regulations:

  • A registered principal must review any social media site that an associated person intends to use for a business purpose, and they must review it in the form in which it will be “launched.”
  • Participating in an interactive electronic forum is considered a “public appearance” and does not require prior approval by a registered principal, but firms must have procedures in place so they can review such participation after the fact to make sure such communication doesn’t violate Finra or SEC rules.
  • Unlike communication on interactive forums, “static” posts — such as blogs or other writing on Web pages — are considered “advertisements“ and must be approved by a registered principal before they are posted. 
  • A person affiliated with a broker-dealer may respond to a business-related question, such as one about a security, that’s posted on his or her Web site, provided that the b-d doesn’t have policies prohibiting such participation. If a firm has a policy that associated persons may not use a personal social media site for business purposes, then a substantive response by the associated person would violate this policy.

Audit Requirements

Engage121 also enables financial institutions to keep an audit trail enabling compliance with these updated regulations.

  • Brokerage firms must keep records of all communications pertaining to business, even if they are made on a personal device such as a laptop or smart phone.

If you are wondering how to manage these challenges, please give us a call or contact us .



Insurance and Social Media

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At Engage121, Inc. we have clients in numerous industries.  In the coming weeks, we will be posting about social engagement as it relates to specific sectors.

Here’s a question we’ve heard from our many insurance clients:
“What’s the most important thing an insurance company needs to know in Social Media?”

Answer: What are our own agents saying?!?

This is a logical place for any marketing, operations, customer service, or other unit within an insurance brand to start.

1. Are their posts working against your messages?

2. Are their posts inconsistent with your best practices?

3. Are their posts focusing on selling services instead of engaging?

4. And, most important, is their activity compliant with FINRA’s guidelines?

It’s easy to find out with the right tools. It’s essential to do if your brand is going to use Social Media at all.

Using a Social CRM interface, you should be able to instantly see a snapshot of what your agents are saying right now, across Twitter, Facebook, LinkedIn, their own blog if they write one, and any other social network you’ve chosen to plug into your “corporate” interface. You should be able to view everything they are saying, or filter down by those posts specifically about the brand or other keywords.

Also, let’s not only look at this as a “gotcha” tool. After all, you don’t want to play social cop all day. Plus there may be some great, appropriate content that your agents are posting. Your field agents are the front line, talking with customers face-to-face daily, and know your brand’s services better than anyone. Perhaps there’s some content they are posting that could be repurposed and shared to via your corporate fan pages or blogs.

Can a tweet take you down? FINRA busts financial broker for tweets

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If you dashed out of work early Friday, you probably missed the New York Times online article that reported that FINRA, the Financial Regulatory Authority, busted a rogue broker with a $10k fine and one year suspension for sending “misrepresentative and unbalanced” tweets (Twitter Messages Land Broker in Trouble). If you’re a broker/dealer or run a financial firm, I know what you’re thinking: Could your last tweet be 140 career-ending-keystrokes?

Well, you can relax,…just a little.

The busted California broker was not exactly caught by meticulous detection of a few errant tweets. This gal left a cyber trail of Canned Hams. First, she tweeted stock-hyping tips constantly and failed to disclose material information about the stock picks, including her ownership of some of the securities she was shilling. Second, she maintained two different web sites that displayed misleading information about her career accomplishments. Third, she failed to tell her firm about not one or two or three but thirteen private brokerage accounts she held on the side. Oh, and then there was the issue of potential impropriety as she was moonlighting as a jewelry executive.

But what about all you other financial brokers and dealers? Can a tweet take you down? Here are a few things to ponder that may clear the air.

1. How does FINRA decide what’s a safe tweet?

In January of 2010, FINRA published Regulatory Notice 10-06, providing “Guidance on Blogs and Social Networking Web Sites.” The nexus of the ruling was not some high tech nuance born from the advent of social media. It’s actually based on a 12 year old ruling about Chat Rooms. Essentially the March 1999 ruling deemed that all Chat Room conversations between a financial representative and a customer “are subject to the same requirements as a presentation in person before a group of investors.” Notes from in-person presentations had to be archived for possible future audits. Likewise, any conversation exchanged in a Chat Room has to be archived for possible future audit. FINRA’s Reg 10-06 essentially extends the Chat Room regulation to social media sites.

Keeping a record of a Chat Room conversation is actually easier than recording notes about an in-person meeting because the “chat” is already typed. The financial organization just needs a means of capture and archive. The tricky part is Chat Room conversations were held “in one room”. Conversations in social media can start with a tweet, get reposted to Facebook and/or migrate to blogs and other social venues. I chatted last year with Tom Pappas, co-author of Regulation 10-06 and VP/Director of Advertising Regulation at FINRA. He said there is no software or tool that a company can use to automatically comply with the FINRA guidelines. Bottom line: Financial firms are required to retain records of communications related to the broker-dealer’s business that are communicated through social media sites.

2. What are financial firms doing about this?

Many banks and financial firms are dealing with this risk by not dealing with it. Simply stated, they block their brokers, dealers and employees from accessing social sites like Twitter and Facebook at work. I spoke to my personal local bank (name withheld) about their policy. They also block access to social sites on work computers. I asked the branch manager if he had a smart phone in his pocket–at his desk–that had access to facebook and twitter. He laughed with me at the point I was making. He showed me the banks communications policy. Employees can submit ideas for tweets and Facebook posts–via email to the corporate communications office at HQ. CorpComm then screens the posts and may decide to post them at a later date. As you can imagine, few if any employees submit posts to CorpComm (and their social media presence lacks a personal touch as a result). Other financial organizations have strict guidelines about not mentioning any work related items when an employee uses social media for personal reasons from home or vacation.

3. Are any financial firms doing it right?

The smart ones (in my view) are embracing social media as a new means of engaging new and existing customers. Morgan Stanley now allows 18,000 wealth management advisors to use Twitter at work, as long as all tweets are first approved by the firm. So while Morgan Stanley’s advisors are now engaging prospects and customers through social media, other firms are staring at a phone that doesn’t quite ring as much. Full disclosure: financial organizations using Engage121 range from Edward Jones, Geico and smaller institutions like Cambridge Community Bank.

4. How can I learn more about using Social Sites and still comply with FINRA?

- Start by reading Regulatory Notice 10-06 found at www.finra.org. Page nine of this ten page document has a wealth of EndNotes referencing other sites and podcasts on the topic.
- Second, you can find the social media communications policies of many corporations on their sites. These are reference points to help you understand how others are complying with Reg. 10-06.
- Third, ask FINRA. Reach Tom Pappas via telephone: 240-386-4500, or Joseph Price, FINRA’s SVP of Adverting Regulation/Corporate Financing at 240-386-4623.
- Finally and almost poetically, you can follow FINRA News on Twitter at: http://twitter.com/#!/FINRA_News