Because Raymond James sees the value in social media, they have hired Hearsay Social for archiving. With the vendor expenses and staffing costs, all together Raymond James is paying millions of dollars, and is absorbing that sum so it does not come directly out of the advisors’ pockets.

To post, advisors have to go through the Hearsay social tool, a native site. If individuals go directly to Facebook through their browsers, it will not be captured.  Another drawback is that the Hearsay tool for mobile use has not yet been activated. 

Advisors can use Hearsay to mass distribute content through multiple channels.

Raymond James Compliance Advice
“When discussing social media with regulators, they are still trying to figure it out (too),” said Cuillo.

He pointed out some Finra rules and expectations. He referenced content standards under Finra Rule 2210(d)(1) and that advertising needs to be fair and balanced. For example, "Peace of mind" has been deemed to be misleading. Advisors need to hedge with language like, "No investment is guaranteed."

Finra also requires that the member name be disclosed. They will also look for suitability, so be careful promoting something like a double leveraged ETF to all social networks.

Cuillo gave examples of problematic images. “You can’t use a picture of money, but it might be ok if you are talking about the money supply.  It is not ok if you are talking about your asset allocation strategy,” said Cuillo.

Regarding photographs of clients, Cuillo advised, “If you are going to do close ups of your clients, we suggest you do a photo release. It is not a regulatory requirement, but you don’t want to get sued.”  The example of a wife seeing a photo of her husband with someone other than her was an example that got some laughs.He noted that it is a tight regulatory environment and there will be increased scrutiny.

In 2013 the Raymond James compliance team reviewed 30,000 ads and 160,000 pages, with an average turnaround time 1.1 days.

An Observation
The tweeting at the Raymond James national conference was low for its size. With 3,500 attendees, the hashtag #RJFSNCPD should have been more widely used. It hit me that if there is a limitation in leveraging social media use from smartphones, it is going to greatly diminish real-time communications. I did find it as proof of the importance of “mocial” (Marketing Lingo You Must Add To Your Vocabulary).