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	<title>Comments for Socialware Blog | Social Middleware Discussion</title>
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	<link>http://blog.socialware.com</link>
	<description>The Social Middleware Company</description>
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		<title>Comment on Gartner&#8217;s social software predictions for 2010 and beyond by Joshua Baer</title>
		<link>http://blog.socialware.com/2010/02/22/gartners-social-software-predictions-for-2010-and-beyond/comment-page-1/#comment-1086</link>
		<dc:creator>Joshua Baer</dc:creator>
		<pubDate>Sun, 28 Feb 2010 02:37:05 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=435#comment-1086</guid>
		<description>Social isn&#039;t going to replace email, social is going to move back to email - as we&#039;re already seeing with Myspace and as is predicted with Facebook (they have not actually announced anything, TechCrunch just wrote a story about a rumor).

Social today reminds me of the early ISPs. Do you remember when AOL, Prodigy, and Compuserve all had silos of mail systems and you couldn&#039;t email from one to another? SMTP replaced all that and made it so that you can send email between any of the networks. The same thing will happen (and already is happening) with social. Facebook messaging won&#039;t replace email - it will become email.</description>
		<content:encoded><![CDATA[<p>Social isn&#8217;t going to replace email, social is going to move back to email &#8211; as we&#8217;re already seeing with Myspace and as is predicted with Facebook (they have not actually announced anything, TechCrunch just wrote a story about a rumor).</p>
<p>Social today reminds me of the early ISPs. Do you remember when AOL, Prodigy, and Compuserve all had silos of mail systems and you couldn&#8217;t email from one to another? SMTP replaced all that and made it so that you can send email between any of the networks. The same thing will happen (and already is happening) with social. Facebook messaging won&#8217;t replace email &#8211; it will become email.</p>
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		<title>Comment on Gartner&#8217;s social software predictions for 2010 and beyond by Adam</title>
		<link>http://blog.socialware.com/2010/02/22/gartners-social-software-predictions-for-2010-and-beyond/comment-page-1/#comment-1013</link>
		<dc:creator>Adam</dc:creator>
		<pubDate>Mon, 22 Feb 2010 23:57:27 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=435#comment-1013</guid>
		<description>Even more so now, IT needs to be a thought leader on topics like social networking and collaboration. However, most technology teams at corporations are still in a reactive mode to their business stakeholders. We need more IT leaders how can associate to how fast trends like social networking are moving and help loosen the reigns for their employees to innovate instead of the desire to lock all the technology down.

I think some of this social networking news is just making lots of noise, but companies can&#039;t just put their heads in the sand and hope it goes away. Like outsourcing in the late &#039;90s, this trend is here to stay.</description>
		<content:encoded><![CDATA[<p>Even more so now, IT needs to be a thought leader on topics like social networking and collaboration. However, most technology teams at corporations are still in a reactive mode to their business stakeholders. We need more IT leaders how can associate to how fast trends like social networking are moving and help loosen the reigns for their employees to innovate instead of the desire to lock all the technology down.</p>
<p>I think some of this social networking news is just making lots of noise, but companies can&#8217;t just put their heads in the sand and hope it goes away. Like outsourcing in the late &#8217;90s, this trend is here to stay.</p>
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		<title>Comment on New research report on the use of social at work by Adam</title>
		<link>http://blog.socialware.com/2010/02/11/new-research-report-on-the-use-of-social-at-work/comment-page-1/#comment-730</link>
		<dc:creator>Adam</dc:creator>
		<pubDate>Fri, 12 Feb 2010 22:08:24 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=398#comment-730</guid>
		<description>For most Financial Services firms, social media is likely shut down unless the firm already has their social media policy in place. However, you have a great point about people using alternative means of access such as an iPhone to do the same thing. At some point, financial services firms are going to have to figure this out.</description>
		<content:encoded><![CDATA[<p>For most Financial Services firms, social media is likely shut down unless the firm already has their social media policy in place. However, you have a great point about people using alternative means of access such as an iPhone to do the same thing. At some point, financial services firms are going to have to figure this out.</p>
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		<title>Comment on FINRA Webinar: Compliance Considerations for Social Networking Sites by Adam</title>
		<link>http://blog.socialware.com/2010/02/03/finra-webinar-compliance-considerations-for-social-networking-sites/comment-page-1/#comment-727</link>
		<dc:creator>Adam</dc:creator>
		<pubDate>Fri, 12 Feb 2010 20:45:02 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=382#comment-727</guid>
		<description>Chad, good job providing a timely recap of the webinar. In the meantime, I have provided a complete spotlight on the 7 main points of the FINRA webinar. You can check it out here: http://bit.ly/cZ1O1Q and I would love to hear your thoughts.</description>
		<content:encoded><![CDATA[<p>Chad, good job providing a timely recap of the webinar. In the meantime, I have provided a complete spotlight on the 7 main points of the FINRA webinar. You can check it out here: <a href="http://bit.ly/cZ1O1Q" rel="nofollow">http://bit.ly/cZ1O1Q</a> and I would love to hear your thoughts.</p>
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		<title>Comment on FINRA Webinar: Compliance Considerations for Social Networking Sites by Stephanie Sammons</title>
		<link>http://blog.socialware.com/2010/02/03/finra-webinar-compliance-considerations-for-social-networking-sites/comment-page-1/#comment-572</link>
		<dc:creator>Stephanie Sammons</dc:creator>
		<pubDate>Wed, 03 Feb 2010 23:57:56 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=382#comment-572</guid>
		<description>Chad, thanks for the overview and the play by play.  Very helpful given that there will not be a replay for several weeks from what I understand.  Looks like you guys are on top of it with your platform!</description>
		<content:encoded><![CDATA[<p>Chad, thanks for the overview and the play by play.  Very helpful given that there will not be a replay for several weeks from what I understand.  Looks like you guys are on top of it with your platform!</p>
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		<title>Comment on Just released: Companion Guide to FINRA Social Networking Compliance by Adam</title>
		<link>http://blog.socialware.com/2010/01/26/just-released-companion-guide-to-finra-social-networking-compliance/comment-page-1/#comment-564</link>
		<dc:creator>Adam</dc:creator>
		<pubDate>Wed, 03 Feb 2010 18:00:20 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=352#comment-564</guid>
		<description>Thanks for the companion guide. I too see nothing really new in the notice, but do appreciate the four or so iterations of what requires and does not require prior approval. I wrote up my take on the FINRA notice at this link: http://bit.ly/d84X1N and will be creating a follow-up summary after today&#039;s call.</description>
		<content:encoded><![CDATA[<p>Thanks for the companion guide. I too see nothing really new in the notice, but do appreciate the four or so iterations of what requires and does not require prior approval. I wrote up my take on the FINRA notice at this link: <a href="http://bit.ly/d84X1N" rel="nofollow">http://bit.ly/d84X1N</a> and will be creating a follow-up summary after today&#8217;s call.</p>
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		<title>Comment on Just released: Companion Guide to FINRA Social Networking Compliance by Chad Bockius</title>
		<link>http://blog.socialware.com/2010/01/26/just-released-companion-guide-to-finra-social-networking-compliance/comment-page-1/#comment-446</link>
		<dc:creator>Chad Bockius</dc:creator>
		<pubDate>Tue, 26 Jan 2010 18:17:45 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=352#comment-446</guid>
		<description>Karen - let me expand on this. FINRA states the following in Notice 10-06 “As a general matter, FINRA does not treat posts by customers or other third parties as the firm’s communication with the public subject to Rule 2210. Thus, the prior principal approval, content and filing requirements of Rule 2210 do not apply to these posts. Under certain circumstances, however, third-party posts may become attributable to the firm. Whether third-party content is attributable to a firm depends on whether the firm has (1) involved itself in the preparation of the content or (2) explicitly or implicitly endorsed or approved the content.” 

So FI’s still need to be careful. For example, republishing a comment from a third-party, such as Retweeting, will likely be considered an endorsement by the firm. Additionally, “Favoriting” a post on Twitter or “Liking” a comment on Facebook could also be seen as an endorsement by the firm.

Our recommendation to our clients is to educate reps about the dangers of endorsing a third party post and depending on your risk tolerance disable the ability to Favorite or Like a Tweet or comment.  

Retweeting is more complicated as a representative might be retweeting a perfectly acceptable message. In this situation you may want to adopt a policy and solution that provides pre-posting moderation for any retweeted messages.</description>
		<content:encoded><![CDATA[<p>Karen &#8211; let me expand on this. FINRA states the following in Notice 10-06 “As a general matter, FINRA does not treat posts by customers or other third parties as the firm’s communication with the public subject to Rule 2210. Thus, the prior principal approval, content and filing requirements of Rule 2210 do not apply to these posts. Under certain circumstances, however, third-party posts may become attributable to the firm. Whether third-party content is attributable to a firm depends on whether the firm has (1) involved itself in the preparation of the content or (2) explicitly or implicitly endorsed or approved the content.” </p>
<p>So FI’s still need to be careful. For example, republishing a comment from a third-party, such as Retweeting, will likely be considered an endorsement by the firm. Additionally, “Favoriting” a post on Twitter or “Liking” a comment on Facebook could also be seen as an endorsement by the firm.</p>
<p>Our recommendation to our clients is to educate reps about the dangers of endorsing a third party post and depending on your risk tolerance disable the ability to Favorite or Like a Tweet or comment.  </p>
<p>Retweeting is more complicated as a representative might be retweeting a perfectly acceptable message. In this situation you may want to adopt a policy and solution that provides pre-posting moderation for any retweeted messages.</p>
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		<title>Comment on Just released: Companion Guide to FINRA Social Networking Compliance by Karen</title>
		<link>http://blog.socialware.com/2010/01/26/just-released-companion-guide-to-finra-social-networking-compliance/comment-page-1/#comment-443</link>
		<dc:creator>Karen</dc:creator>
		<pubDate>Tue, 26 Jan 2010 16:08:58 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=352#comment-443</guid>
		<description>Chad,
Thanks for the post. Can you elaborate on the following: &quot;FINRA clarified that posts by customers or other third parties are not governed by rule 2210.&quot; What does this mean with regard to those posts? 
If a customer or third party not under the FI&#039;s control posts something inaccurate, what action is the FI required to take, and within what time frame? Thanks.</description>
		<content:encoded><![CDATA[<p>Chad,<br />
Thanks for the post. Can you elaborate on the following: &#8220;FINRA clarified that posts by customers or other third parties are not governed by rule 2210.&#8221; What does this mean with regard to those posts?<br />
If a customer or third party not under the FI&#8217;s control posts something inaccurate, what action is the FI required to take, and within what time frame? Thanks.</p>
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		<title>Comment on Just released: Companion Guide to FINRA Social Networking Compliance by Chad Bockius</title>
		<link>http://blog.socialware.com/2010/01/26/just-released-companion-guide-to-finra-social-networking-compliance/comment-page-1/#comment-440</link>
		<dc:creator>Chad Bockius</dc:creator>
		<pubDate>Tue, 26 Jan 2010 14:47:57 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=352#comment-440</guid>
		<description>Static content would be information like your Twitter profile details or your LinkedIn profile - content that is generally &quot;static&quot;.  Wall posts or status update or tweets would all be considered dynamic content. 

So while pre-approval is not required under these new guidelines they do encourage firms to employ &quot;risk-based principles&quot; to determine the appropriate type of review. The options available are pre-approval or post-use review. I suspect most firms will opt for the post-use approach, doing an audit of archived content to ensure compliance.</description>
		<content:encoded><![CDATA[<p>Static content would be information like your Twitter profile details or your LinkedIn profile &#8211; content that is generally &#8220;static&#8221;.  Wall posts or status update or tweets would all be considered dynamic content. </p>
<p>So while pre-approval is not required under these new guidelines they do encourage firms to employ &#8220;risk-based principles&#8221; to determine the appropriate type of review. The options available are pre-approval or post-use review. I suspect most firms will opt for the post-use approach, doing an audit of archived content to ensure compliance.</p>
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		<title>Comment on Just released: Companion Guide to FINRA Social Networking Compliance by Theresa</title>
		<link>http://blog.socialware.com/2010/01/26/just-released-companion-guide-to-finra-social-networking-compliance/comment-page-1/#comment-439</link>
		<dc:creator>Theresa</dc:creator>
		<pubDate>Tue, 26 Jan 2010 14:21:12 +0000</pubDate>
		<guid isPermaLink="false">http://blog.socialware.com/?p=352#comment-439</guid>
		<description>After reading the notice, I&#039;m still not 100% sure that tweets would not be subject to pre-approval.  Or are they leaving this up to the b/d to decide what exactly is &quot;static&quot; and what is &quot;dynamic&quot;?  

Also, at one point they say that a &quot;wall&quot; is &quot;static.&quot; So would wall posts on facebook need to be pre-approved?

I&#039;m interested to hear how other b/d&#039;s are interpreting the rules.</description>
		<content:encoded><![CDATA[<p>After reading the notice, I&#8217;m still not 100% sure that tweets would not be subject to pre-approval.  Or are they leaving this up to the b/d to decide what exactly is &#8220;static&#8221; and what is &#8220;dynamic&#8221;?  </p>
<p>Also, at one point they say that a &#8220;wall&#8221; is &#8220;static.&#8221; So would wall posts on facebook need to be pre-approved?</p>
<p>I&#8217;m interested to hear how other b/d&#8217;s are interpreting the rules.</p>
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