Should you Disclose your Social Media Content?

Posted by Alex Rowe on March 27, 2013

Social media has previously not been an issue when it came to your SEC or other public filings, but that may be changing...  

Since mutual funds and other investment companies are required to submit certain advertisements for review by the Financial Industry Regulatory Authority (FINRA), many are taking the pre-cautionary step of submitting their social media content as well.

Although it is not mandatory for most social media releases to be cleared, companies are taking the extra step as a safety measure. The Division of Investment Management released information today which helps clarify what does and does not need to be cleared by them to be shared.

 “Today’s inaugural IM Guidance Update on social media is intended to help firms strengthen their compliance efforts by providing meaningful real life examples in a format that is accessible to all on the SEC’s website,” said Norm Champ, Director of the Division of Investment Management. “We expect future guidance updates will highlight other relevant issues for funds, advisers, and the public.”

 To read more on the matter and see examples of what should and shouldn't be filed, visit the SEC's Update:http://www.sec.gov/divisions/investment/guidance/im-guidance-update-filing-requirements-for-certain-electronic-communications.pdf

Tags: Internal Controls, social media, best-practice, FINRA, disclosure, Vibato, SEC, Division of Investment Management