This week, FINRA posted on its website a Targeted Examination
Letter entitled "Spot-Check of Social Media
Communications" ("Social Media Letter"). FINRA
occasionally posts Targeted Examination Letters to alert its
members to specific focus areas. The Social Media Letter defines
"social media" to include such things as Facebook,
Twitter, LinkedIn and blogs. Given the proliferation of social
media throughout virtually all facets of our daily lives, it is not
surprising that FINRA is attempting to understand and evaluate how
its membership is using those devices. The Social Media Letter
indicates that FINRA is particularly interested in developing
information about the compliance programs in place for social media
usage. In short, the Social Media Letter is a wake-up call to
broker-dealers that they need to implement the necessary control
structure and supervisory processes before permitting the use of
social media for marketing, communications or solicitations.
