The Socially Savvy Advisor + Website: Compliant Social Media for the Financial Industry

AppendixSample Social Media Policy

Here is a model social media policy prepared by Stuart Fross, partner at Foley & Lardner LLC. © Foley & Lardner, LLC 2014.

Use of Social Media

Policies and Procedures

1. Statement of Policy

The Advisor's use of social media is governed by this policy. Social Media is defined as Facebook, Twitter, YouTube, LinkedIn, as well as Internet blogs and other interactive forums.

Any use of social media by the Advisor:

• Must be accurate and not fraudulent, deceptive, manipulative, or misleading,
• Must not omit to state material information,
• Must comply with all internal guidelines and applicable rules associated with advertising,
• Must comply with this policy, and
• Must be reviewed prior to use by the Chief Compliance Officer (CCO) or his/her designee.

The Advisor's use of social media shall be governed by and employees shall comply with the following compliance policies and procedures:

A. Advisor Accounts. The Advisor may establish its own social media accounts with the prior approval of the CCO. The approved social media sites are as set forth in Exhibit 1.

The Advisor will allow only the individuals specified in Exhibit 2 to post information on its behalf to social media.

B. Personal Sites Prohibited from Business Uses. No personal social media account or web page may be maintained by an individual employee for any business use. A business use will be inferred from any reference to the Advisor, to any fund or investment strategy, except that an employee ...