Helping the financial industry adopt social networking

Facebook Wall Posts: Always static?

Would all *initial* posts by an advisor to his/her Facebook wall be considered static? I'm not thinking about responses, but say they start a conversation like "what are your concerns in 2011?".

If not, what would constitute it as dynamic if ever? Is there general consensus on this?

Thanks,
Joe

▶ Reply to This

Replies to This Discussion

Permalink Reply by Alex Wingert on February 9, 2011 at 6:03pm

Hey Joe,

When posting to a Facebook wall, it is considered static because you cannot change the content, only delete it. If there were an edit option for wall posts then it might cross over into dynamic, but for the time being wall posts are static.

▶ Reply

Permalink Reply by Joe Rueckert on February 10, 2011 at 9:18am

Not sure I understand. A tweet can only be deleted after being published. By that logic, wouldn't tweets be considered static? My understanding is tweets are generally considered dynamic.

I didn't think the editability of the content was the key factor. If you have more support info on that, I'd appreciate it.

Joe

▶ Reply

Permalink Reply by Loic Jeanjean on February 10, 2011 at 1:47pm

Hi Joe,

you can actually read more about this topic on social ware blog: http://blog.socialware.com/2010/01/26/just-released-companion-guide...

If people can interact with your posts (i.e comment or share) it is considered dynamic...

Loic

▶ Reply

Permalink Reply by Joe Rueckert on February 11, 2011 at 2:27pm

Loic, I guess what I'm concerned about is the wall posts. 10-06 specifically uses language of "Wall information" as static and never parses "wall posts" specifically as dynamic. It does talk about Interactive Posts, which I would interpret to be wall posts.

I know I'm being a little too exact with language, but that's the legal argument I'd get when determining. It sounds like your interpretation (and likely the broader community) would see it as dynamic, as I would. Just wondering if there's been any more explicit language from FINRA to support that.

Thanks

joe

▶ Reply

Permalink Reply by Stephen Selby on February 16, 2011 at 11:06am

Under current FINRA guidance Wall posts are static when they initiate a discussion. They are interactive for subsequent posts 2...n.

The first post can be scripted and reviewed by corporate compliance departments prior to posting. Follow up "likes" and comments are more fluid in nature like a public appearance ( for additional background see FINRA Regulatory Notice 07-59 http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents...)

It is the fluid or "interactive" nature of posts 2 ... n which merits different treatment.

In FINRA terms, you need to treat the first post as an advertisement, subsequents posts can generally be treated as public appearances.

Please let me know if this helps.

Best regards,

Stephen Selby

▶ Reply

Permalink Reply by Joe Rueckert on February 16, 2011 at 12:12pm

Thanks Stephen (and everyone). Stephen, your summary is consistent with how I view it. Does FINRA state anywhere specifically the "first vs subsequent" posts or is that just the general consensus? I'm trying to legitimize that conclusion to leave no ambiguity.

joe

▶ Reply

Permalink Reply by Stephen Selby on February 16, 2011 at 12:25pm

In 2010 I moderated a panel on social media at LIMRA's Regulatory Compliance Exchange (our compliance conference). One of the panelists was Joe Price, one of the authors of RN 10-06. I don't want to put words in his mouth, but I believe my earlier post would be an accurate reflection of Joe's position based on our prep work and the conference panel.

I will add that it may be possible to script subsequent comments, insofar as comments can be anticipated.

▶ Reply

Permalink Reply by Albert Armendariz on July 11, 2011 at 9:54am

Hello Everyone,

I believe the consensus here to be that Facebook wall posts are considered interactive content. One question that arose regarding that definition concerns the topic of sharing. For example, often times third party websites will allow a Facebook user to share an article. The act of sharing an article allows the user to post the third party web link to the article along with a picture of the website (automatically imported by Facebook). The Facebook user could also add text when adding the link to their wall, for example "This is an interesting article, please read." With that said, my question surrounds the posting of the third party link on the wall.

Would this posting be considered interactive content, and thus subject to post principal review or would the act of posting the third party link be considered posting a third party reprint, and subject the link to pre-review? I understand that any extra verbiage an advisor would post, such as my above example, would be interactive content. However it seems that posting a third party link may be subject to principal pre-review.