Social Media FCA Compliance Guidelines 2014
Resources for financial services firms preparing for the new UK Financial Conduct Authority Social Media Guidelines
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17 June 2014
Presented to 250 Delegates
At Financial Services
Social Media Event, London
@simonjryan
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Who Is This Guy?
I RunI Run
Simon Ryan
For Clients
Like
This
For Clients Like This
Award WinningAward Winning
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Back In The Day
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Brave New World
Promotions and communications made
using new media must meet the
requirements for stand-alone compliance.
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FCA Changes Since June 2010
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Except in May 2013
"What’s new is that
we won’t just be
relying on regulatory
reports back from
firms, but on reports
from consumer
bodies, internet
monitoring, the
media and even on
Twitter.”
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And Then In December 2013
The Financial Conduct Authority
(FCA) is to publish social media
guidance for financial services firms
early next year [2014].
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Half of
those
polled
had a
mortgage
Let’s Remember Why It’s Important
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So What Are We Expecting?
No one knows for sure.
However, the recent US
FFEIC guidelines suggest:
Prepare for
risk management and
corporate
accountability.
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1. Content
2. Strategy and Governance
3. Monitor, Moderate and Measure
4. Audit and Archive
4 Main Themes
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We don’t expect any changes to the current Financial
Promotions Guidance
However, we do expect
•Some kind of internal staff accreditation for staff with
social media accounts, like money laundering
•A process for who has authority, access and scope
•Be able to monitor staff activity in social media
– Including personal activity for authorised people
1. Content
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• Define what you intend to/not to achieve
– The scope for your social media activity
• Carryout a Risk Assessment
– Produce a Risk Register
• Appoint one person to own all of these
– Make sure they report at least quarterly
– Have someone interested and with authority for them
to report to
2. Strategy & Governance
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3. Monitor, Moderate & Measure
Firstly, Customers
•Define how you will monitor what is being said
about your brand, products and business
•Define how you will respond
– How will you take it offline?
•Report on activity volumes to inform risk
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3. Monitor, Moderate & Measure
Secondly, Staff
•Be clear about which staff you will monitor
•Say how you will monitor your staff
•Record breaches and lessons learned
•Have a staff policy for social media just as you
would speaking to the press
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• Record all the activity of your firm and staff
• Keep a complete archive – that means by user
• Record compliance/guideline/policy breaches
and remedial action taken
• Be prepared for FCA spot checks
Especially if you have
agents, branches, brokers or adviser networks
4. Audit and Archive
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Thank you
Simon Ryan
T: 0800 092 4046
E: simon@socialadvisors.co.uk
@SocialAdvisorUK
More Resources
adviserpost.co.uk/social-media-compliance
Summary
No further changes from the FSA or FCA since 2010, except
Summary
When I started looking at social media at the end of 2009 for Aviva there were no compliance guidelines, the truth was, no one knew what was acceptable to the regulator.
Summary
In June 2010, the UK’s financial services regulator, the FCA, joined the USA, Canada and India in publishing social media compliance guidelines. In just two pages it essentially said whatever applies to other forms of media, applies to Social media.
Summary
No further changes from the FSA or FCA since 2010, except
Summary
FCA Head, Martin Wheatley, did say that the FCA would start monitoring activity
http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/9958341/Financial-Conduct-Authority-chief-Martin-Wheatley-will-use-Twitter-to-spot-companies-illegal-activities.html
http://www.moneymarketing.co.uk/chris-jackson-how-will-the-fca-monitor-social-media/1068825.article
Summary
Just under the radar of Christmas, the FCA announced there would be new social media guidelines in Q1 2014
Summary
No one knows for certain what the FCA has in mind, we have seen little formal consultation and no reports of major issues in the current social media guidance. However, we can reasonable expect the FCA to want to harmonise with the US guidelines given they are ahead of UK adoption. The most recent and ubiquitous guidelines for financial services social media came from FFEIC.
Summary
We think there are 4 main themes that the FCA needs to address and that we can take away from the recent new US guidelines produced by the FFEIC.
At the core of these are deciding what you are trying to achieve (strategy), setting out to track this (governance), how you will monitor in order to take remedial action and how you will record everything for later review.