You’ve developed a social media policy? CHECK.
You have your procedures, training, archiving and technology solutions running? CHECK, CHECK and CHECK.
You have an on boarding process where your advisors can opt into your program, pay their fees and register their social media accounts? CHECK and CHECK!
You have a program that scans the web, making sure that your reps aren’t joining social networks or creating websites that haven’t been pre-approved….ummmm.
We recently spoke with a broker dealer that possesses robust policies, utilizes a great technical solution, deploys solid on boarding processes, accompanied with a training programing and review processes. What was the one gap in their program? In a recent audit, a FINRA examiner found a few examples of advisors who had active social media accounts on LinkedIn and Twitter that were missing from the firm’s social media program. Why were some advisors missing from their program? Likely the advisor failed (or forgot) to report the accounts to compliance, but more importantly, the firm clearly failed to find it through proper supervision.
How did the examiner find these rogue social media accounts? You guessed it. Google™.
To comply with SEC and FINRA supervision requirements, some firms have employed a cumbersome strategy involving manual web searches. Typically these firms will dedicate hours upon hours each year doing tedious Google™ searches on their representative’s first and last name, and perhaps another search involving the representative’s DBA. We’ve spoken with a number of firms that use this approach and they run into quite a few challenges such as:
- Non-Unique Names: Do you know many James Cella’s there are in the United States? According to one site, there are over 50 individuals in the U.S. that share my name, which is a lot considering it’s not a very common name! If you’re searching for an advisor by the name of Aaron Brown, you’re looking at over 3,100 individuals that share that name, many of which have Facebook, LinkedIn and Twitter accounts and more. Without the assistance of an automated solution, it can be terribly difficult to even find the right James Cella or Aaron Brown without looking through hundreds and hundreds of results.
- Noise: Often search attempts are cluttered with “white noise” that distracts the searcher from their main purpose of providing supervision. “Noise” can come in many forms including results from sites that aren’t important to your purposes like classmates.com, or business directories like spokeo.com. Over time, this “noise” leads to misses in the supervision process and adds to the firm’s risk of regulatory fines or penalties.
- Search Depth: Manual searches typically return 10 results per page and most searchers only check 1 to 3 pages, giving them a limited scope of results.
- Search Breadth: The breadth of a web search is defined as the dynamic nature of your search. Most searchers execute a narrow search array consisting of just a first and last name. A more dynamic search would consist of using multiple data points in varying combinations which would widen your supervision net and effectiveness.
- Documentation: As firms perform manual searches, a major concern quickly arises: “How can we effectively document this process?” Proper documentation of manual searches can be an overwhelming task, especially considering all the moving pieces involved like screenshots, spreadsheets, and comments along with the date and time stamps needed to show evidence that supervision has occurred. Combining and connecting your documentation can be difficult as well.
- Manpower: Some firms we’ve spoken with face a huge challenge in finding the necessary manpower needed to effectively execute a manual supervision process, which often results in it remaining as a “wishlist” item for a very long time.
- Stretched Supervision Intervals: The manual nature of these searches often limits firms from performing them as often as they would like, which leads to large gaps in the supervision process that could easily allow them to miss a rogue social media account.
Eagle Eye uses multiple data point searches and domain blacklisting to solve both Non-Unique Name and Noiseissues. With mega ranked results and automated searches, it searches at a proper Search Depth and Search Breadth to find elusive threats your manual searches are missing. Eagle Eye’s Documentation is a breeze as it automatically generates documentation as you review your results and creates one-click audit reports. Manpower isn’t is an issue anymore as the system is constantly tracking your results and only bringing new ones to your attention. Stretched Supervision Intervals is a problem of the past as Eagle Eye is constantly scanning the web and documenting what was found, when it was found, and who reviewed it.
With a tool like Eagle Eye, your social media program will finally have that missing piece of the puzzle you’ve been looking for: Web Supervision.