tailieunhanh - National Examination Risk Alert: Investment Adviser Use of Social Media

On an increasingly capacity-constrained railway, and in particular on the main radial routes shared with long-distance services, one emerging option is for the introduction of a high- acceleration, higher-speed commuter EMU to make optimum use of route capacity without major route infrastructure spend. This EMU might be based on existing rolling stock types but could differ from it as well, depending on the capability and commercial terms that bidders negotiate with suppliers and financiers. A potential deployment is between Paddington and Oxford and Newbury; similar opportunities may exist on other strategic routes. Some development work on train/OLE6 interfaces. | National Examination Risk Alert By the Office of Compliance Inspections and Examinations1 In this Alert Topic Observations related to the use of social media by registered investment advisers. Key Takeaways Investment advisers that use or permit the use of social media by their representatives solicitors and or third parties should consider periodically evaluating the effectiveness of their compliance program as it relates to social media. Factors that might be considered include usage guidelines content standards sufficient monitoring approval of content training etc. Particular attention should be paid to third party content if permitted and recordkeeping responsibilities. Volume II Issue 1 January 4 2012 Investment Adviser Use of Social Media I. Introduction Social media2 is landscape-shifting. It converts the traditional two-party adviser-to-client communication into an interactive multi-party dialogue among advisers clients and prospects within an open architecture accessible to third-party observers. It also converts a static medium such as a website where viewers passively receive content into a medium where users actively create content. The use of social media by the financial services industry is rapidly accelerating. In growing numbers registered investment advisers RIAs or firms are using social media to communicate with existing and potential clients promote services educate investors and recruit new employees. Pursuant to Advisers Act Rule 206 4 -7 3 firms using social media should adopt and periodically review the effectiveness of policies and The Securities and Exchange Commission SEC as a matter of policy disclaims responsibility for any private publication or statement by any of its employees. The views expressed herein are those of the staff of the Office of Compliance Inspections and Examinations in coordination with other SEC staff including in the Division of Enforcement s Asset Management Unit and the Division of Investment Management and do