FINRA Series 6 Investment Company and Variable Contracts Products Representative ExaminationProfessional Conduct and Ethical ConsiderationsMedium

A registered representative is reviewing their firm's policies on social media use. The policy states that all professional communications on social media must be pre-approved by a principal. The representative frequently posts market commentary on their personal LinkedIn profile. Which action is REQUIRED for the representative to remain compliant?

  1. AOnly post general market trends and avoid specific investment recommendations.
  2. BLimit social media activity to non-professional content only.
  3. CEnsure their LinkedIn profile clearly states that their views are personal and not those of their firm.
  4. DObtain pre-approval from a principal for each market commentary post.
Show answer & explanation

Correct answer: D. Obtain pre-approval from a principal for each market commentary post.

The firm's policy explicitly requires pre-approval for 'all professional communications' on social media. Market commentary, even on a personal profile, is considered professional communication and thus requires principal pre-approval.

Why the other options are wrong

  • A. This might reduce risk, but it doesn't satisfy the firm's pre-approval requirement for professional content.
  • B. This is an option, but not necessarily 'required' if the representative wishes to continue posting professional content.
  • C. While good practice, a disclaimer does not negate the need for pre-approval as per firm policy.

Social Media Pre-Approval (FINRA)

Many FINRA member firms require pre-approval by a principal for professional communications posted by registered representatives on social media platforms, even personal ones.

  • Applies to content deemed 'professional communication'.
  • Aims to ensure compliance with advertising and communication rules.
  • Firm policies can be more stringent than FINRA's general rules.

Memory trick: Social posts for work: get a principal's nod, or it's a fraud.

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