FINRA’s Focus On Social Media

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.