Yo, yo, yo – the Securities and Exchange Commission (SEC) is at it again! They want access to what they consider an advisor’s full risk profile, which includes social media profiles. Advisors need to be aware of this substantial change, which affects the filing of Form ADV and additional reporting requirements. You have until Oct. 1, 2017, to be prepared, but there’s no time like the present, right?
If you’re not familiar, Form ADV is used by investment advisors to register with the SEC, to register with one or more state securities authorities, and amend those registrations.
The update has to do with Section 1.I of Schedule D. The current form asks you to list your website (And FYI: You must have a separate form for EACH website). The new form will not only ask you for your website, but it will also ask you to provide all your corporate social media accounts, including Facebook, Twitter, LinkedIn, etc. The final ruling can be found here. Not too bad so far, right?
First of all, you want to be sure you file your forms correctly. More importantly, this ruling really speaks to the extra eyeballing you can expect on your corporate social media accounts. Today, your compliance likely requires you to archive and retain your social media posts and content. If they don’t, you can expect that shoe to drop soon!
Not all archive software is built alike. If you’re using more popular platforms such as Actiance, Hearsay, Smarsh, FMG Suite, etc., you will have fewer worries when your accounts are audited. I’m sure there are other archive/retention platforms out there, but these are the four I come across most often and have the most familiarity with.
You have until Oct. 1, 2017, to comply, but you shouldn’t delay in handling this change. The SEC is no joke. Make sure your archiving provider is on their game. Make sure your staff understands the additional filing requirements. And, make sure you’ve touched base with your compliance officer so they know you’re on top of it.
Sheryl Brown knows firsthand that social media can amplify your value proposition — and she wants to show you how. As Social Media Engagement Manager at Ash Brokerage, she assists advisors and employees with their own social media strategies, and she has been influential in developing a strategic online presence for Ash Brokerage — one that connects to both clients and advisors, positively impacts practices and creates communities aimed at improving the industry.
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