Last week, FINRA announced it has started to perform ‘spot checks’ of social media communications, including posts on Twitter, Facebook, LinkedIn and blogs, for some of its member firms.

The new social media spot check comes as no surprise. It’s been over three years since FINRA started talking to regulated firms about social media with its first official social media guidance. Each year, FINRA has continued to keep social media under the microscope, and has updated guidance along the way. FINRA has stressed the importance of developing social media policies and procedures, loud and clear.

Now that FINRA will examine how its members actually use social media, what should broker dealers do to get ready for these spot checks? Since FINRA is keeping a closer eye on social media, here’s how to prepare:

Implement the most up-to-date FINRA guidance into your social media policies and practices. Have a strong, logical social media policy in place at your firm, and review all FINRA guidance notices to ensure the policy reflects them. Your social media policy is an active document, signed by your firm’s representatives, that outlines exactly how (and why) employees may use social media; who may use your firm’s social media accounts; and which social media platforms and accounts can be used for business communications. Your reps should understand that the social media policy will be enforced and activities monitored closely. In the event of a FINRA spot check, your policy will help explain why certain social media activities are sanctioned.

Note: Even if your firm forbids the use of social media for business communication, make sure you still have this stance documented, as an official social media prohibition policy. Ensure that your reps follow the prohibition policy, and enforce it. Be prepared to demonstrate to FINRA that your policy is working, by investigating and correcting any ‘rogue’ company use of social media, just as FINRA surely will.

Enforce your social media policies. After your reps have read and signed your firm’s official social media policy, it’s time for training, so they understand and follow the policy rules on a daily basis. Ongoing training in social media best practices is a must, since practices will change over time as social media platforms and FINRA guidelines evolve. Key training topics include: What’s personal vs. business social media; what social media messages need to be approved before they are posted, and which are reviewed after posting; and how to manage third-party social media content.

Supervise and archive your firm’s social media activity. An archiving solution will allow you to capture official records of your firm’s social media posts-and search, supervise, and produce those records in their original format for future reference. You’ll also want to archive and monitor messages from your firm’s approved accounts on several different social media platforms, and accommodate new platforms as needed. Your website and blog (including images, videos, text and audio) should be archived, so you have a solid record of material published online that demonstrates your reps meet FINRA requirements there as well.

Your compliance team needs the ability to demonstrate they’ve reviewed your firm’s social media posts, and can confirm who’s evaluated and approved each post. Make sure you can track the whole lifecycle of each social media message, including the exact date and time it was created (or deleted), and show the precise actions taken by the compliance team when a social media issue needs to be followed up on or addressed. This type of audit trail can help back up and substantiate your social media activities during a FINRA spot check or full examination, and provide automated evidence that your reviewers are enforcing policies.

For broker dealers, social media compliance is now essential. Even if your firm’s reps follow the guidelines in your social media policy, and have been trained on social media use, archiving is still a safeguard to show that you’ve captured and addressed any missteps.

Don’t be one of the firms caught off guard with a social media spot check; prepare and get ready for it now.