• “I followed the process. I asked them, ‘What do you need from me in order to get this approved or allow this to happen?’ and I listened and I did that. It takes a lot of work, but I would do it. I would submit, I would get their feedback, I would make the changes, I would resubmit. And I think they knew that I was taking this seriously. And then they were more willing to work with me.”
• Be careful about putting opinion in your posts. Compliance officers prefer the posts be fact based.
• Social media posts need to be archived and available when a regulator walks through the door.
• “Am I fully compliant? I’m not sure because there’s still a lot of questions about what’s fully compliant for social media. But at least I want to show that I’ve made an effort with having a policy and procedure and being able to store all my posts.”
• The most important issue to CCOs is to have a social media policy in place and a procedure for tracking what’s being posted.
• Practices are monitored very closely to ensure that procedures are followed and claims aren’t being made on social media that can mislead investors in any way.
• “The thing we’re concerned with is being the first mouse in the compliance trap. We’d rather analyze what the others currently are doing with social media and see how that fares with regulators, and implement policies around what’s already been tried and tested.”
Charles Massimo, founder of CJM Wealth Management:
Bob Bacarella, founder of asset manager Monetta Group
Jerry Gleeson is senior editor and community manager for Finect, based in Greenwich, Conn.