The Leaders Group, Inc. welcomes the use of social media sites such as Facebook, Twitter and LinkedIn by its registered representatives as a means of contacting existing and prospective customers. The purpose of these policies and procedures is to detail how these sites can be used while remaining in compliance with all applicable rules and regulations.
Social media communications are subject to the same compliance standards as written communications. Specifically, they are subject to FINRA review, recordkeeping, and filing requirements. SEC Rule 17a-4 requires the firm to preserve copies of all such communication relating to the member’s business for a minimum of three years.
FINRA Rule 2210 stipulates that all communications must be fair and balanced, with no misleading statements or omissions of material information. Further, any false, exaggerated, unwarranted, promissory claims or guarantees are prohibited.
All LinkedIn individual pages are required to be archived. However, please note that company pages containing non-investment related content, such as items relating to fixed insurance, do not need to be archived. No solicitation of business is allowed on any social media site. Avoid making recommendations, endorsements and promotions of any specific products or services.
Finally, please keep your business page separate from your personal page. A profile or page created for professional use must be used only for professional activities. Personal profiles or pages must be used only for personal activities. Recognizing this difference will keep The Leaders Group from any intrusion into your personal life.
Cost of Monitoring Social Media Content
The Leaders Group, Inc. uses Global Relay as its third-party vendor to capture and archive social media content. All representatives who elect to use Twitter or LinkedIn individual pages for business purposes must sign up with Global Relay so that their content can be archived electronically. The cost for this service is included with the compliance and technology fees. The use of Facebook or LinkedIn company pages is not included and is subject to an additional fee of $45.00 per quarter per page. Please reach out to the Compliance team, firstname.lastname@example.org, to have this set up.
The Leaders Group will search for Social Media accounts periodically. If you are found to have a social media account containing securities keywords or a LinkedIn individual page, a link will be sent to your archived email address for you to immediately sign up through Global Relay or remove your securities-related content. Non-compliance with our social media policies is grounds for having your payment withheld, fines, and if chronically ignored, termination.