Social Media Archiving for Broker-Dealers

Social Media Archiving for Broker-Dealers
Overview
Features
FINRA Notice 10-06

Social Media Is Here To Stay

The business power and potential of social networking websites like Facebook, LinkedIn and Twitter is undeniable. Unfortunately, so are the compliance risks.

Social media compliance solutions from Smarsh give your firm the preservation, supervision and policy controls to embrace social networking with SEC and FINRA compliance peace of mind. Thoroughly and efficiently navigate the recordkeeping, suitability and supervision requirements of FINRA Regulatory Notice 10-06.

All messages are captured, preserved in their native form and indexed in the secure Smarsh archive. Posts can be searched and produced on-demand. All administrator activity is logged and quantifiable, providing evidence of enforcement and means to evaluate a reasonably designed policy. Firms can automate policy company-wide, define which social networking features employees have access to, and review, approve or reject messages before they are posted.

Our suite of social media archiving and compliance solutions enable member firms to preserve, index, search, review and produce social network postings on-demand from Twitter, LinkedIn, Facebook and embrace emerging regulatory requirements.

Smarsh Social Media Archiving

Capture and Preserve  |  Control and Enforce  |  Search  |  Supervise  |  Produce

Capture and Preserve 

Social media traffic is captured via proxy or through APIs.
  • Flexible integration | The Smarsh platform is designed to support the unique business needs of our clients rather than requiring our clients to alter or modify their processes to fit our technology. Smarsh supports multiple means of capture and provides flexible integration options. Capture activity from inside or outside your network, including from mobile devices.
  • Seamless user experience | Depending on the implementation type, the Smarsh solution can provide end-users with a seamless Facebook, LinkedIn, or Twitter experience.
  • Accessibility | Archived social media data is readily accessible via the web-based Smarsh Management Console. Content never goes off-line (unless specified by the client).
  • Redundant data centers | Content is preserved in the redundant, geographically-dispersed Smarsh data centers and saved to WORM (write once, read many) optical storage. 
  • Retention policies | Messages are retained in accordance with client retention policies (and active legal holds).
  • Compliance | Meet SEC & FINRA compliance requirements, such as message storage in unaltered formats on tamper-proof media, independent third-party attestation, and full audit trail of review activity.

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Control and Enforce 

Depending on the implementation type, Smarsh offers policy controls for your organization's social media users.

  • Establish controls | Define and enforce which features on social networking sites that employees can access.
  • Pre-review/Moderation | Review, approve and reject messages before they are posted.
  • Policy Enforcement | Enforce corporate policies governing the use of social networking websites. 
  • Brand Management | Manage your brand's presence on social networking sites.

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Search 

Administrators can search across their email and electronic message archives based on virtually any criteria, either ad-hoc or on a consistent, systematic basis.

  • Robust field search | Smarsh indexes the entire electronic message, and enables search by Boolean combinations of virtually every associated field, including: network, message body, sender, recipient, post type (status update, tweet, comment, etc.) and message date and time.
  • Saved searches | Save search criteria and repeat searches for convenience, consistency and evidence of policy enforcement.
  • E-discovery searches | Run robust ad-hoc discovery searches for one-time instances.
  • Support for multiple lexicon lists | Clients can customize company-approved lexicons of keywords/phrases for search and/or start with a default list provided by Smarsh.
  • Multiple social media networks and screen names | Search traffic of multiple social media networks per employee.

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Supervise 

Your supervision procedures are not at the mercy of inflexible technology. Customize your firm's supervision experience for optimal efficiency in message review and effectiveness in identifying and mitigating risk. 

  • Hierarchy structure | Permission-based review hierarchy can be configured to model the review structure of your organization. Administrators can assign message supervision roles/authorities to specific users and groups, and grant the appropriate level of access/functionality to them. Smarsh can grant temporary permissions or access to compliance consultants, outside legal counsel or other individuals.
  • Run saved searches | Execute review procedures with regularly scheduled saved searches.
  • Flexible search options | Match search type (random percent, risk score, keywords or phrases) to risk profile.
  • Contextual review | Track the entire thread of a social media post from multiple individuals, giving a conversation context during review.
  • Full audit review | Every administrator session and action taken throughout the entire lifecycle of a message is documented within the Smarsh Management Console.
  • Take action on messages | Reviewers have the ability to annotate, flag, open/close or escalate messages. All actions are logged and the subsequent metadata is indexed and searchable.
  • Reporting Center | Produce analytics reports on corporate social media usage, system audit history and social media archive data. Demonstrate policy enforcement and ensure accountability among multiple managers responsible for message review. Reports can be customized.

Produce 

Administrators can retrieve and produce as many messages as necessary, in original form, on demand. 

  • Production options | Content can be securely downloaded to a PC or encrypted and saved to a portable media device. This can be utilized for real-time access to data during an investigation or examination, or to restore data for disaster recovery purposes.
  • Flexible e-discovery export | Export message data in popular e-discovery vendor “load file” formats (and the Electronic Discovery Reference Model (EDRM) XML Interchange Format Schema) and transfer it directly to document review and processing systems.
  • Monthly DVD service | As part of its service package, Smarsh delivers monthly copies of client data via encrypted DVD.

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Regulatory Notice 10-06 Highlights

  • Firms are required to archive and supervise communications to protect consumers from undue risk.
  • Rules apply to firms and personnel using sites for business purposes (defined by the content of the message, not where site is accessed).
  • Social networking sites have both static and interactive content. For example, Twitter posts or Facebook status updates are considered interactive. Profile information is static, requiring preapproval.
  • Static content must be moderated or preapproved by a principal.
  • Interactive content does not require mandatory pre-approval. However, firms must supervise interactive content in a manner reasonably designed to ensure they do not violate communications rules.
  • Customer complaints must be acknowledged and followed up within 15 days.
  • FINRA is prepared to bring disciplinary action for violation of rules and securities laws

Visit the FINRA 10-06 page in the Smarsh regulations and laws database for more information.

Use the filters below to find regulations and laws relevant to you and your company.