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Best of 2018: 8 Components of a Social Media Policy

Editor’s note: Until the end of 2018, we will be revisiting the top five blog posts of 2018. The first post is from Claudio Pannunzio and it is the very definition of an oldie but goodie. This post originally appeared in 2012 but continues to be one of our most-viewed posts every year since. This year, it claimed the No. 1 spot on the most popular blog posts of 2018. See this evergreen post on the eight components of a social media policy for your financial planning firm. 

Engaging in social media activities can be a wise and rewarding decision for a large number of advisers. However, many issues need to be addressed prior to deploying a social media communications strategy. One of the most important issues is implementing a sound social media policy that provides a blueprint for interaction and establishes clear rules to ensure proper adherence to compliance.

The goals of a social media policy are straightforward:

  • Establish rules and procedures for all users when using social media sites
  • Facilitate users’ understanding of their responsibilities when engaging in online communication
  • Promote and maintain compliance within all FINRA, SEC and other applicable rules

Let’s now have a look at some of the basic components you should consider when creating a social media policy for your practice:

1. Purpose
State why your firm is engaging in social media and the scope for putting in place a policy governing its use. This will help everybody in your organization attain a solid understanding of the reasons behind the firm’s social media engagement.

2. Definition
Define what you and your firm regard as social media and how your firm will leverage the various social media platforms to communicate with its external audiences.

3. Users
Determine the professionals authorized to contribute to social media sites on behalf of your firm, specify what activities these individuals should be engaged in and establish who will be in charge of monitoring their activities.

4. Ownership
Define the professionals responsible for creating and selecting social media content and establish posting guidelines and schedules.

5. Content
The information you will provide via social media platforms is of critical importance. Clearly spell out the type of information that can and cannot be divulged via social media, unmistakably emphasizing what is considered proprietary or confidential information.

6. Employee Conduct
Establishing a code of conduct will help you achieve two strategic goals:

  • ensure that communication is consistently transparent, ethical, accurate and adheres to compliance rules; and
  • prevent employees in their personal social media interactions from inadvertently or casually stating their affiliation to your firm without your formal approval, knowledge and control.

7. Communication Risks
Establish general guidelines and best practices for the different platforms your firm is planning to use, referring to the FINRA and SEC compliance regulations. Create a list of subjects that should never be discussed and/or posted on social media, such as confidential information, financial details, legal matters and proceedings, as well as libelous or defamatory information, obscene images/content, information infringing third party’s intellectual property rights, copyrights or trademarks.

8. Negative Comments Protocol
We strongly recommend to all our adviser clients to develop a well-defined protocol on how to handle a third party’s negative posts/comments on social media platforms. These can include tactics such as acknowledging the negative comment and offering a solution; immediately deleting inappropriate comments of threatening, profane or obscene nature; or setting up social media accounts to not allow any posts/comments.

Claudio Pannunzio

Claudio Pannunzio is the managing director of Cürex Group Holdings. He was formerly the president of i-Impact Group Inc. in Greenwich, Conn.


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10 Steps to a Great First Meeting

Engaged team members need to know how they influence the success of the business. (4).pngYou’ve finally gotten a meeting with that top prospective client you’ve been trying to meet for weeks, maybe even a couple of months. Congratulations!

Now what? If you’re like many planners, you’re excited to have finally landed the appointment, but perhaps a little apprehensive about making sure the meeting goes well.

Here are 10 steps you can take to pave the way for a successful introductory conversation.

  1. Do your homework. Google, LinkedIn, Facebook and other online resources can provide a wealth of information about your prospective client. However, keep in mind that you’re not compiling a dossier but simply looking for potential areas to explore—their employment, where they live, their family, organizations they’re part of and activities they enjoy.
  2. Determine the specific result you want to have from the meeting. What do you want your prospective client to think, or more importantly to do, as a result of having met with you? Is your goal that you mutually agree that you’re a good fit? Do you want them to schedule a discovery meeting or send you their statements? Be specific.
  3. Write out an outline or structure for the meeting that you believe will enable you to achieve your desired result. Think about creating the best flow. The better you plan for the meeting, the more likely it will be successful.
  4. Confirm the meeting with your prospective client. Send a calendar invitation, and then follow up to confirm the day before your meeting with an email, text message or phone call. Reiterate how much you are looking forward to your time together.
  5. Be intentional about what you take along to the meeting. A notepad is a must. A couple of simple one-pagers (your bio, your differentiators, your process) that support your story can be much more valuable than a slick marketing brochure or research piece.
  6. Focus on learning about them. Demonstrate a client-first mindset. Ask questions. Show genuine interest in their story. The more you learn about your prospective client, the more you will be able to connect your story to theirs.
  7. Know what you plan to say. If they aren’t a good fit for what you do, communicate that. Share that based on what they’ve shared about themselves and what they need from a financial adviser or planner, as well as how you typically serve your clients, you don’t think you’d be a good fit for them (or, cost effective for them) at this point. Be kind. Communicate that you’re not right for them, not that they’re not right for you.
  8. Describe what differentiates you. If they are a good fit for you, tell them how you’re different from other advisers and how you believe you can help them. Conclude with, “Based on everything you’ve told me about yourself and what you need, and how I typically serve my clients, I think we’d be a good fit to move forward to our discovery process.” Then stop and wait for their response.
  9. Set expectations. Assuming they agree (and why wouldn’t they?), set clear expectations for next steps and gain their agreement.
  10. Always follow up with a note of thanks, recapping the key takeaways from the meeting and confirming those next steps. Your note can be handwritten on a card (more personal) or by email (much faster).

Remember, everything you say and do communicates a message to your prospective client. Make certain it’s the message you intend.

Enjoy a productive meeting with your next client!

Susan Kornegay Headshot

Susan Kornegay, CFP®, is a partner at Pathfinder Strategic Solutions. After more than 30 years as a financial adviser, branch manager and practice management consultant, Kornegay enjoys helping financial planners define a comprehensive and consistent client experience and then market that experience in clear, client-friendly language. She is a coach, along with Adam Kornegay, RCC™​ in the Messaging and Marketing Strategy FPA Coaches Corner.


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Money Manager Analysis: Issues and Considerations

Engaged team members need to know how they influence the success of the business. (5).pngThere are many ways in which advisers can serve the best interests of their clients. Some advisory firms with the background and expertise within the firm choose to directly manage their clients’ portfolios. Others may choose to focus their time on financial planning needs and “outsource” the investment management.

Regardless of how an adviser decides to operate, it’s important that a firm’s disclosure documents are in line with what they are doing and that the firm is properly registered. Regulators will scrutinize firm’s disclosure documents for accuracy. The focus of this piece is to help advisers who outsource (or plan to outsource) the investment management to third-party money managers understand their situation so they can properly answer the disclosure questions in the SEC’s forms ADV 1, ADV 2A and ADV 2B, and determine whether the structure of the third-party money manager relationship makes sense for their situation.

Issues and Considerations

Consider the following potential issues and considerations when working with third-party money managers.

  1. What is the true nature of your firm’s relationship with the third-party money manager(s)?
  2. Are you acting as a solicitor?
  3. Is the third-party money manager acting as a sub-adviser?
  4. Under this relationship, what services are you providing clients versus the services that the third-party money manager is providing?
  5. How are you compensated? How is the third-party money manager compensated?
  6. How do you disclose the true nature of the relationship on your ADV disclosures?
  7. When the third-party money manager is engaged, is the client still considered a client of yours?
  8. If they are deducting fees, but it is “your client”:
    • Are they doing it properly under the custody rule?
    • Are they billing in advance for a period of more than six months (triggering audited financials for you if it is “your client”)?
  9. Is it your policy not to have discretion?
    • If so, does the third-party money manager trade with discretionary authority?
    • Are you responsible for approving their trades? (If you approve recommended changes without prior client approval, you are likely violating your policy and taking discretion.)
  10. How does the outsourcing of the investment management impact your firm’s value proposition?
  11. What is the reputational risk of working with third-party money manager(s)?
  12. If things go wrong with a specific client account, can they disclaim liability because it is your advisory account?

Due Diligence

During your due diligence process, discussions with sales representatives (or relationship managers) of the third-party money manager will often provide you with the general information you need to answer the above questions. That said, it may serve you well to read through the third-party money manager’s actual documents (Form ADV, agreement between your firms and the advisory agreement your clients will sign), even though it will require additional time and analysis.

The devil is in the details. Additionally, when push comes to shove, these documents will likely be at the center of determining: (1) whether your firm’s disclosures are accurate; as well as (2) ultimate responsibility on any issues at arise.

Todd Skoda

Todd Sakoda brings 20-plus years of experience in the financial services industry ranging from compliance and operations to business development and relationship management. His last 12 years has focused on independent registered investment advisory firms. Over his career, he has also worked with independent broker-dealer advisers and bank investment programs. He, along with John Carr, is a coach in the Compliance FPA Coaches Corner.