Regulatory/Legal Focus: SEC, FINRA, FTC, General Liability
Featured Code: CMP.LY/F
In addition to FTC guidelines, financial services firms have to also address SEC and FINRA disclosure requirements and compliance in their social media communications. In some cases, financial services firms will be able to meet their compliance needs by employing the same codes used by unregulated companies; in other cases, stricter regulatory requirements will require that companies attach disclaimers or disclosures specific to their industry. By using the CMP.LY/F code, our clients can address these requirements across a broad range of activities including marketing, public relations, investor relations, and agent and employee communications.
CMP.LY includes high-value tracking, reporting, and analytics to help financial services companies measure, manage, and optimize their social campaigns and programs. Example uses of our products for the financial services industry are listed below (please note: We encourage you to consult with your legal counsel for recommendations on which CMP.LY products and codes best meet your needs).
MARKETING: CONTESTS, PROMOTIONS & SPECIAL OFFERS
Product + Disclosure: Promotional + CMP.LY/R
I want to run a social media contest, promotion, sweepstakes, or special offer (e.g., credit card offer), but want to limit legal exposure and optimize consumer participation by ensuring that rules, terms, and “fine print” are consistently and clearly communicated to consumers.
Solution: Simply generate a CMP.LY/R code through our Promotional product and include it in your message content to ensure your rules, terms, and other “fine print” are included and conspicuous to consumers across social media channels.
MARKETING: INFLUENCER MARKETING PROGRAMS (BRAND AMBASSADORS, BLOGGER OUTREACH, ETC.)
Product + Disclosure: Network + CMP.LY/0-5, Custom, CMP.LY/R, or CMP.LY/F
I wantto use individuals I have identified as influential and/or knowledgeable to promote my brand or product as a part of a marketing initiative, but I need to address FTC guidelines that require me to ensure my influencers are disclosing their connection to my brand and that I am able to monitor for compliance and take action if needed. I also want to measure the performance of my campaign and each participant.
Solution: Simply use the CMP.LY Network product to set up your program, select applicable disclosure(s), and invite individuals to participate. CMP.LY does the rest, ensuring that program participants review and accept your policies; confirming that they include appropriate disclosures when communicating in authorized social media channels; providing alerts if they breach compliance; documenting any follow up action you take; and providing high-value campaign metrics.
AFFILIATE PROGRAMS: INDEPENDENT AGENT DISCLOSURES
Product + Disclosure: Enterprise + CMP.LY/A, CMP.LY/F
I want to enable my independent sales force to communicate with clients through social media and ensure that my commissioned agents comply with SEC, FINRA, and FTC regulations when communicating with consumers.
Solution: Simply use the CMP.LY Enterprise product to set up your program, select applicable disclosures, and invite designated users/networks to participate. You will then be able to enable dynamic disclosure generation consistent with the content of your agents’ messages. CMP.LY does the rest, ensuring your agents review and accept your policies; confirming that they include appropriate disclosures when communicating in authorized social media channels; providing alerts if they breach compliance; documenting any follow up action you take; creating a searchable archive of all their communications; and providing high-value program measurement and metrics.
CORPORATE COMMUNICATIONS: CONTENT DISSEMINATION VIA OFFICIAL COMPANY CHANNELS
Product + Disclosure: Corporate + CMP.LY/F
I want to use my corporate social media channels to distribute firm materials such as research reports, but need to attach all the necessary disclosures, disclaimers, and warnings regarding suitability, conflicts of interest, and other issues required by the SEC and FINRA.
Solution: Simply generate a CMP.LY/F code through our Corporate product and use it to link to every report you distribute through social media. This ensures that all the necessary disclaimers and disclosures are automatically included and conspicuous to investors as you distribute across social media channels.
EMPLOYEES: IR COMMUNICATIONS
Product + Disclosure: Corporate + CMP.LY/F
I want to live-tweet my quarterly earnings call, but I need to include my Safe Harbor disclaimers and meet my public disclosure requirements under Reg FD.
Solution Recap: Simply generate a CMP.LY/F code through our Corporate product and use it to link to every update you post through social media. This ensures that all the necessary disclaimers and disclosures are automatically included and conspicuous to investors as you distribute across social media channels. In addition, CMP.LY’s automatically generated audit trail will serve as documentation of simultaneous widespread release of information in compliance with Reg FD.
By using CMP.LY, public companies can responsibly engage investors via social media channels. Use CMP.LY/F to address regulatory disclosure requirements associated with distribution of content or materials, earnings reports, and other announcements.
EMPLOYEES: BROKER DISCLOSURES
Product + Disclosure: Enterprise + CMP.LY/F
I want to make it possible for my brokers to use social media to interact with their clients, but need a way to include all the necessary disclosures, disclaimers, and warnings regarding suitability, conflicts of interest, and other issues required by the SEC and FINRA that can change depending on the content and timing of my brokers’ messages.
Solution: Simply use the CMP.LY Enterprise product to set up your program, select the CMP.LY/F code, and invite users/networks to participate. Your brokers will be able to enter information regarding their current holdings and you will be able to enable dynamic disclosure generation consistent with the content of your agents’ messages.
CMP.LY does the rest, ensuring your brokers review and accept your policies; confirming that they include appropriate disclosures when communicating in authorized social media channels; providing alerts if monitored messages are out of compliance; documenting any follow up action you take; creating a searchable archive of the content of all their communications; and providing high value campaign metrics.
