(This is a guest post from Stephen Selby, Director of Regulatory Services at LIMRA.)

As social media users in financial services have discovered over the past couple of years, it’s tough to build a business in a swamp. It makes me think of the King of Swamp Castle from Monty Python and the Holy Grail.

Listen, lad. I’ve built this kingdom up from nothing. When I started here, all there was was swamp. All the kings said I was daft to build a castle in a swamp, but I built it all the same, just to show ‘em. It sank into the swamp. So, I built a second one. That sank into the swamp. So I built a third one. That burned down, fell over, then sank into the swamp. But the fourth one stayed up. An’ that’s what your gonna get, lad—the strongest castle in these islands.

Social media regulation has been a little like Swamp Castle. FINRA released Regulatory Notice 10-06, and built a foundational concept for all of us to follow—all the old rules apply. But the financial services industry as a whole did not believe that foundation was solid enough. We let the first castle sink into the swamp.

Then FINRA released Regulatory Notice 11-39. The financial services industry again said that foundation was not strong enough, so we again let social media fall into the swamp. Foreign regulators like the FSA in Great Britain and the IIROC in Canada published social media guidance in their own countries. The National Association of Insurance Commissioners issued its own white paper on social media. The messages from the FSA, IIROC, and NAIC all tracked well with FINRA’s core message—all the old rules apply. But the financial services industry was not happy with that foundation yet and, even with all of the positives, watched social media again fall into the swamp.

January 2012: The Fourth Castle of Social Media Regulation

Now we have both the SEC and the Commonwealth of Massachusetts issuing guidance for Registered Investment Advisors. To paraphrase the King of Swamp Castle—I am here to tell you what you’ve gotten—the strongest castle in these islands! We have seen securities regulators, insurance regulators, and now RIA regulators all say the same things: Yes, social media is an exciting new form of communication. Yes, we will apply existing rules to this new technology. It should be clear that we are no longer standing in a swamp, but on the strong foundation of a consistent message.

Let’s see how that consistent message applies to RIAs in the Commonwealth of Massachusetts. I will present these points in a different order than communicated by the Massachusetts Securities Division their memo of January 18, 2012. This order should help you structure your approach to social media for RIAs:

• Social Media is subject to supervision. Have a plan. Document it. Test the plan at least annually.
• Training. No policy or procedure is very good unless people know what it is. Therefore training is a really good idea.
• The firm is responsible for all business content. It’s social media time. Do you know what your investment advisor representatives (IARs) are saying?
• Social media is subject to record-keeping requirements. You will need a method of capturing and retaining social media content in a manner consistent with SEC retention rules. (For more, see 950 CMR 12.205(7)(a) and 17 CFR 275.204-2.)
• Frequent supervision is better. Massachusetts states on page 6 of their document “A review done daily would be considered a reasonable supervision of the adviser’s social media site.” Less frequent review can be acceptable—if you have low traffic volumes.
• Social media is usually advertising under RIA rules. Go back to the basics and apply current advertising content and supervision standards for RIAs to social media. Performance reporting via social media is subject to the same content and time standards as any other kind of media. Cherry picking past performance is not permitted. Recommendations are not permitted.
• Adoption and Entanglement applied across regulators. RIAs are responsible for content which they post, Tweet, re-Tweet, or like, or to which they link. RIAs are also responsible for content which is posted on behalf of their representatives by business partners or anyone else who has an interest in the success of the IAR. Selective removal of some content results in the “adoption” of the remaining content.
• “Liking” can be Problematic. To completely understand what Massachusetts is saying about the “Like” button, I encourage you to read SEC Regulation FD and the recent SEC risk alert. The key take-away is that your firm is responsible for any content which is “Liked” by the firm or an IAR. Make sure it’s good content.
• Read the SEC guidance. Massachusetts makes reference to recent SEC guidance on social media usage.

More Best Practices for Social Media Compliance

The Massachusetts document “The Use of Social Media by Investment Advisers” is not intended to tell the whole story. Here are a few ideas you need to consider beyond the recent guidance provided by the Commonwealth.

• Put clear license and registration disclosures in social media profiles. This will help insulate the firm against the appearance of soliciting where the firm is not registered.
• Update the firm’s Code of Ethics. Not all states require a code of ethics, but communicating a standard and then training your people to that standard is always a good idea.
• Face-to-face supervision is a best practice. Take time to review the computers and mobile devices of IARs when visiting satellite offices.
• Understand what is being said about you by solicitors and other business partners. You may need to review agreements to specifically address the use of social media.
• Get help, but take responsibility. Social media use and supervision is ultimately up to you, but Socialware and LIMRA can help get you going.

In closing, think of the King of Swamp castle. “All the other kings” may say you are daft for using social media when there are so many questions, from ROI to compliance. Prove them wrong. Now that regulators for the securities, insurance, and investment advisory business have spoken, you have a firm compliance foundation on which to build your social media practice.

When so many regulators are saying the same thing—maybe you really do have the opportunity to build the strongest castle in these islands.

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“Social is a shared service that’s used across the enterprise. As such, the CIO is responsible for being the integrator of those solutions.”

Wolberg also talked about how often CIOs, CTOs, CISOs, and other IT leaders are “at the nexus of saying ‘No’,” and how refreshing it can be to be able to say “Yes” to new initiatives or tools that enable better business outcomes—especially in cutting-edge areas like social.

IT as a Leader, Not a Follower, in Social Business

For more perspective on this, I talked with Ken Burbary, a technologist who serves as Vice President and Group Director for Strategy and Analysis at the global agency Digitas. His work puts him in touch with business leaders across different industries who are grappling with the implementation—and the implications—of social business practices.

“IT has a key role in all of these amazing and disruptive innovations. The days of command and control IT are waning, if not over, in most companies. So how can the CIO stay relevant to the business? By clearly articulating how to help internal clients be successful in achieving their goals by leveraging social technologies.”

Burbary is quick to acknowledge that this doesn’t change the IT organization’s dedication to maintaining traditional responsibilities for security, data integrity, and so on. But the approach has to be collaborative. “I’ve found IT departments that try to extend the command and control mentality into business units that are looking to be more agile and leverage disruptive technologies like social fail—they fail miserably and just get shut out and worked around.”

Avoiding the Risk of “Crowdsourced IT”

Burbary’s point was echoed by Adam Cohen, Senior Vice President for Digital and Social Media at Fleishman-Hillard. Cohen, who spent years helping major enterprises implement back-office systems, highlighted the connections between security, risk mitigation, and “crowdsourced IT.”

“If IT says no to an idea sponsored by a business unit without supplying better alternatives, employees may simply go outside the constraints of IT,” Cohen said. “Technology has changed, and people can get a lot done without involving IT if they want to.” Especially in financial services, he added, “employees talking about anything on social networks in an unsupervised or unstructured way is a risk.” In his view, these factors imply that “it’s actually riskier for an IT department not to be involved in social media.”

Again, IT organizations that embrace this viewpoint can become enablers of positive business outcomes for other areas of the company including marketing, compliance, and sales.

CIOs Look to Emerging Best Practices for Social Business

The good news is that you don’t need to go it alone. Flagship enterprises in financial services and other industries are establishing best practices to embrace the social technologies that provide a competitive advantage and improve internal and client-facing operations while maintaining compliance.

These best practices, which we will continue to discuss in future posts, allow IT departments to move away from “the nexus of saying ‘No’.” We’re here to share what we and our partners have learned from enterprises and IT departments across the industry.

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Last week I sat down with Socialware CEO Chad Bockius for our 2012 Predictions webinar, in which we discussed the social media trends he sees emerging in financial services. Now you can listen to the archive of the webinar to hear why Chad thinks that this is the year when social business gets personal, along with his specific predictions for consumers, financial advisors, regulators, and enterprises.

Social Business Questions Advisors and Enterprises Must Answer

Early on, Chad made the observation that “Social is how we live now—not just how we play,” and pointed out that consumers are increasingly turning to their social networks for trusted recommendations on handling their finances. We then talked about a number of issues that financial professionals must address if they want to get the most out of this sweeping change, including:

• What do enterprises need to do to build momentum in social business?
• “Social is the unfair advantage of 2012”—but how engaged does an advisor need to be to expect returns from social?
• What actions can we expect from the SEC and other regulators this year, and what can companies do to be ready?

As you’ll hear in the webinar archive, we left half an hour for Q&A—but still weren’t able to get to all the topics raised by audience members. Here were some of the questions we discussed:

• “Companies are losing support and engagement from the broader firm because only a select few have access to social media. . . . What would you recommend?”
• “Do you have any advice for social networking as it pertains to independent broker/dealers? Is there an added benefit in social media for a B2B-based firm?”
• “When you talk about 100% adoption, are you referring only to the sales force, or to all employees including marketing, product, and support personnel?”
• “We have brokers who are on LinkedIn and they always ask, ‘I’m on LinkedIn, I have connections, now what?’ How would you answer them?”

To hear the discussion around these questions and many others, click here for the webinar archive page. And feel free to leave more of your own questions in the comments on this post.

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This article from InvestmentNews explains the change:

Tweet away: Finra backs off social-media posting regs

While the article is right to emphasize how this change provides a better way forward, advisors can’t just “tweet away” without a second thought. The reality is that post-use filing was always about the content. And it’s still about the content, even though what FINRA is proposing will remove hurdles that have stymied some firms in their use of social media.

Proposed FINRA Changes for Social Media Postings

Here’s the crux of the proposed change, quoted from FINRA’s letter to the SEC of December 22, 2011:

FINRA recognizes that a member may face supervisory and operational difficulties if it is required to file an online forum post given that the member will be supervising such communications in the same manner as correspondence. Accordingly, FINRA is amending proposed FINRA Rule 2210(c)(7) to add a filing exclusion for retail communications that are posted on online interactive electronic forums. Nevertheless, members should be aware that this exemption does not apply to any filing requirement that may arise under either federal law or SEC Rules.

“Retail communication” is a key term here. According to FINRA,

Retail communication would include any written (including electronic) communication that is distributed or made available to more than 25 retail investors within any 30 calendar-day period. ‘Retail investor’ would include any person other than an institutional investor, regardless of whether the person has an account with the member.

Even more important—and the reason to be careful about how you “tweet away”— is the last sentence from the first quote: “. . . this exemption does not apply to any filing requirement that may arise under either federal law or SEC Rules.” If the nature of what you’re discussing, via social media or otherwise, requires a filing, it will still require a filing.

The Medium and the Message: Two Compliance Checkpoints

We can think of firms and advisors as having two compliance “checkpoints” for any message they put out:

• Checkpoint 1: the medium. FINRA and other regulatory bodies have always treated different mediums differently. For instance, they don’t expect an advisor to digitally record an in-person conversation the same way they would archive an e-mail. Over the past few years, social media has presented a host of new challenges to regulators, since it often does not fit neatly with existing regulations that address other mediums. The new FINRA approach changes things up—a lot.
• Checkpoint 2: the message. A prospectus is a prospectus and must be treated like one. Some types of content will always require pre-review; some will always require post-review. The new FINRA approach doesn’t change that at all.

FINRA Is Not Handing Out a “Hall Pass”

For more insight on this, we asked for the opinion of Stephen Selby, Director of Regulatory Services at LIMRA. Here’s what he said:

FINRA content standards and filing requirements must not be confused. FINRA advertising filing requirements merely mandate that certain materials have to be reviewed by FINRA at a particular point in time. Regardless of FINRA filing requirements, content standards always apply. When using social media for “business as such,” clear, accurate and suitable information must be provided, conflicts of interest must be disclosed, and both sides of the story must be told about investments and investing strategies.

Keep in mind that advertising rules are not the whole story. FINRA also looks at public communications through a lens of “Standards of Commercial Honor and Principles of Trade,” which covers a whole range of issues. There have been recent proposed amendments to the new advertising regulations, which would potentially relax FINRA filing requirements for certain limited uses of social media. Any potential relaxation of filing requirements should not be confused with a hall pass.

It’s a real benefit for firms and advisors that FINRA is proposing these changes, and I’m sure it will reduce the headaches for the compliance officers we work with every day. They’ll still need to archive 100% of the social media messages that their advisors send out, but the filing burden will be lower.

But Selby hit the nail on the head: relaxed standards for certain types of messages don’t equate to a “hall pass” for all social media conversations. Firms should create strong, sensible policies for social media, train their advisors appropriately, and make sure that they have the right tools in place to ensure that they can still adequately supervise advisors’ social media use. Regardless of how the regulatory standards evolve, we’ll be here to help.

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There are two lessons to take away from this:

1. The SEC has made social media a priority. After yesterday’s news, it’s clearer than ever that 100% of firms should prepare for social media audits by having strong social media policies and social media archiving in place.
2. There’s no need to be scared of social media. Fraud is still fraud. While the social networks do present many new challenges for advisors and compliance officers, when it comes to shady activities, only the mediums—not the underlying rules—have changed.

The SEC’s Stance on Social Media

A year ago, the SEC fired a shot across the bow when it issued its sweeps letter about social media. (Our CEO, Chad Bockius, analyzed the SEC letter in two blog posts, which you can find here and here.) If that weren’t enough of a call to action for firms and RIAs to take social media compliance seriously, yesterday’s action should be. Social media use is widespread, and the SEC has articulated firms’ responsibility to monitor and archive these communication channels.

The SEC’s main communication this week, “Investment Adviser Use of Social Media,” is sober and methodical. Probably none of it will be news to compliance departments that have been actively working with their firms’ advisors or agents to promote the compliant use of social media to build professional networks and increase business. But the SEC guidance is useful for the step-by-step reminders it gives about creating and enforcing consistent and meaningful social media policies that balance risk prevention with the need to do business at a reasonable pace.

Firms have a responsibility not only to implement such policies, but to carry out active monitoring of advisors. Those that don’t could be fined, even in they have a formal policy of prohibition for social network use, because it is unreasonable to believe that policy alone will protect consumers. In our 2011 year-end webinar, Bockius discussed the need for all firms to prepare for social media audits. This week’s SEC action demonstrates how serious that need is.

Be Vigilant, But Don’t Be Afraid of “LinkedIn Fraud”

The SEC’s pursuit of the Illinois advisor doesn’t mean that firms should fear the use of social media—much less avoid it altogether. Some of this week’s media coverage might mislead social media holdouts into taking this view.

Consider the headline of this (otherwise very good) article from AdvisorOne:

SEC Charges Advisor With LinkedIn Fraud, Issues Social Media Alerts

I was trained as a newspaper journalist, so I know what headline writers are up against: they have to compress the whole story into just a few words. Unfortunately, headlines like this one make it sound like “LinkedIn fraud” is some new category of crime. In fact, the misdeeds being investigated by the SEC represent very old types of financial fraud, but simply carried out over a social network rather than in person, via mail, via e-mail, or over the phone.

The article rightly points this out in its eighth paragraph:

“Fraudsters are quick to adapt to new technologies to exploit them for unlawful purposes,” said Robert B. Kaplan, co-chief of the SEC Enforcement Division’s Asset Management Unit, in a statement. “Social media is no exception, and today’s enforcement action reflects our determination to pursue fraudulent activity on new and evolving platforms.”

Advisors and firms shouldn’t be scared of LinkedIn (or Facebook or Twitter or blogs). Instead, they need to avoid engaging in illegal, unethical, or otherwise prohibited advertising practices . . . just as for every other medium they use.

Regardless of how the story is covered, it’s good to see that the SEC is following through with its commitment to focus on social media. Your firm needs to be ready if the SEC spotlight should fall your way. Is it?

While firms aren’t delaying their move to social in anticipation of these rule changes, it appears we will have to wait to get the official SEC stamp of approval.

On November 1^st the SEC issued a press release calling for public comment on FINRA’s recent amendment and the proposed rule in its entirety. Written comments are due back on Dec 7^th, 2011. It’s unclear how long the process will take following those comments but this delay is going to push the effort well into 2012.

The SEC calls out six specific areas as it relates to comments. Of the six items outlined, number three is the one area that would really impact social media use.

1. The scope of the definition of “institutional investor” for purposes of [Rule 2210]
2. The “reason to believe” standard under Proposed Rule 2210(a)(4)(F)
3. The requirements applicable to internal communications, public appearances and postings in online interactive forums
4. The requirements applicable to communications prepared by research department personnel
5. The scope of the category of associated persons who financial interests would have to be disclosed in a retail communication that includes a recommendation of securities
6. The scope of the proposed exclusion from the content standards as set forth in proposed paragraph 2210(d)(8)

In the initial round of comments Fidelity and SIFMA “opposed the elimination of the term ‘public appearance’ as a communication category, particularly with respect to interactive electronic communications.” They argued that these posts are “more analogous to physical public appearances. They also argued that recordkeeping requirements would be less burdensome if posts on social media websites are considered public appearances.”

FINRA disagreed. They stated they had “already created an exception from the principal pre-use approval requirements for such posts, permitting members to supervise and review such posts in the same manner permitted for correspondence.”

We will continue to watch this process closely and let you know what comments and changes get introduced that would impact the use of social media in the industry.

What do you think about the proposed changes?

FINRA has shared that they will release additional clarification on social media in a few months.  But, we also know that social media is an ever changing landscape, so it’s difficult to provide a black and white answer to the question… Where is the social media compliance bar?

We recently held a compliance forum with over 30 representatives from our customers. As part of that daylong session we discussed many of the answers to the question above. This experience, plus our deployments with more than 100 financial services firms since 2009, have led to the following 6 points that will help you and your firm ensure you are fully compliant. And this is not just opinion, we’ve had multiple clients go through and pass social media regulator audits already this year.

1. Policy- Compliance starts with policy. Regulators, like FINRA, require each firm to have a social media policy in place before opening access. Unlike other forms of electronic communication, social media requires a close look at the data and the activity that users can create and engage in. In addition, social networking sites are constantly changing so firms should plan for updates and think through how policy will flow from a paper document to technology for automation purposes. For more information on setting social media policy you can refer to the Guides we’ve published on the topic here. In addition, I’d encourage you to watch the recorded webinar on setting policy that was part of our joint LIMRA series title the Social Media Adoption Lifecycle.
2. Training- Just like having a policy, training is a requirement from the regulators. Training should cover everything from your policy, associated procedures and even best practices on how to use social media for business purposes. The latter is not a regulatory requirement but does go hand-in-hand with opening up access to new mediums, like social networks. Before recreating the wheel on training be sure to check out solutions from organizations, such as LIMRA, who are experts at training the field on regulatory issues.
3. Content- Archiving social media data is a fundamental requirement of all regulators. We know that social is treated the same as any other form of electronic communication in the eyes of the regulators. The challenge with social is getting all of the data you need to be compliant. You would never accept archiving 70% of your email, so why would that be acceptable with social? As you explore how you will archive social networking information be sure to verify that all data is being captured.
4. Context- To be compliant in social media you need more than just the data created on the sites themselves you need the context as well. Yes, you must have the content that was posted, say a status update, but you also must have the fact that the data was a status update vs. a direct message. The reason is simple. Messages in social networks are not created equally. Depending on the context you must apply different supervisory principles. Context also becomes critical when a post turns into a full-blown conversation. Supervising a post without the context of a conversation is useless. Another challenging aspect of social networks is the concept of personas. Are you operating in a personal mode or a professional one? This is another area where context will serve you well, ensuring you are scrutinizing the right content.
5. Activity- Another area where social networks create unique compliance risk is around the activities of these sites. On LinkedIn, you can accept and display recommendations on your profile. Unfortunately, this is a violation of the  Investment Advisers Act of 1940. That regulation states that you can’t have testimonials inside of advertisements. What about “liking” a comment? Does that create suitability or endorsement concerns? It can. Part of ensuring compliance will be to limit access to these activities that can create risk for the individual and the firm.
6. Supervision- Supervision is fundamental when it comes to the communication of reps to consumers. With social media certain content must be pre-reviewed, as its considered an advertisement, and certain content requires post-review, similar to email or IM. While there is lots of debate on what must be pre-reviewed vs. post-reviewed (we will save this for a later post) it is clear that supervision of social media can create a real burden if the processes and points of integration to existing systems are not managed or thought through. Furthermore, firms must address the real-time nature of this medium. How will you ensure that the field can use these platforms effectively if your processes don’t support timely review?

Evolving? Yes. Impossible to meet the bar?  No, if you plan appropriately and base your decisions on industry best practices and expertise. And one last word of caution. Don’t just plan for the first 6 months of use. Be sure to consider the compliance challenges that are created as you expand your rollout, eventually approaching 100% utilization (check out this research from Morgan Stanley). It happened with email, and my prediction is that it will happen here as well. This puts a premium on getting it right the first time.

The agenda sparked a lot of questions and involvement from the audience including topics such as the empowered consumer and the regulatory environment especially for financial services firms. When Chad Bockius, CEO of Socialware, was asked whether there was truly a high cost of not participating in social media, Chad explained that the train had already left the station.  Firms need to take advantage of the opportunities to build valued customer relationships using social media.  Since this is constantly evolving landscape, there is no perfect time or plan.  If firms wait six months to put the “perfect” plan in place, that plan will no longer address all of the changes that will take place from now until that time.

Addressing practical implications of setting a social policy, Steve Selby of LIMRA explained that the difference between a good and bad social policy is finding the right balance vs. operating at either end of the spectrum of complete prohibition or wide open access.  Steve went on to address audience questions about FINRA regulatory notice 10-06, specifically static vs. interactive content, and guidance from other regulators like the SEC.  Steve explained that we shouldn’t look for  a “sea stage” from an expected FINRA clarification on social media later in 2011.

Edgar Rodriguez of Distribion, Bockius, and Selby all discussed the connection between the relationship dynamics of social networking and the need for technology to assist in the large volume of interactions, and Edgar expanded on the ability to measure the effectiveness of these interactions and provided helpful suggestions for getting the most of the social interactions.  To learn more about the webinar, you can follow the conversation on twitter #socialmediawebinar and view the webinar.

At our recent customer user group meeting, we were impressed by how open and frank our customers were with us, but more importantly with each other.  With a common goal in mind of developing a community that allows sharing of best practices and pitfalls, we spent a day working through a number of challenges and opportunities.

One of the hottest topics that everyone wanted to discuss was static vs. interactive.  When all was said and done, we agreed on two things.  (1) Content (i.e. what is posted) is king regardless of how/where it is posted.  Trying to label specific features of a social network, as static or interactive is a fool’s mission.  And (2) intent is everything – using the term “extemporaneous” to focus your compliance guidance was well accepted by all.

This led us directly into a conversation tied to pre-review and post-review.  Because of the conclusion on static content, it was agreed that pre-review of content is a critical aspect of a compliance solution and without it you cannot truly be compliant.  However, this does not relieve the compliance obligation, which demands that all information available must be captured whether, performed on network or off network (home computers).  It was very reassuring to all attendees when hearing peers confirm understanding of the regulations and ensure they are using the same solution to meet those regulatory requirements.

Part of our conversation focused around the constant changes occurring daily with the social networks.  Everyone was relieved to hear Socialware’s approach to addressing these changes through our agile product management and development strategy.  This was reaffirmed when Facebook announced a new video chat feature through a partnership with Skype. On that same day, we released a blocking filter should you choose to block this functionality for your users.

Personally, it was a very enjoyable day watching so many of our customers across numerous companies interact with each other.  We all walked out in the afternoon smarter and more educated for the time spent.  I’m looking forward to the next one already.

We recently asked top firms in the industry to share the most pressing compliance concerns within their organizations or from colleagues across financial services companies.  The responses shared both the challenges and opportunities that social networks present for business today.  

There was overwhelming feedback that there is still a lot of room for clarity and ensuring that restrictions are consistent with the nature of the social medium.  Some feel that the rules are out of date compared to the ever changing technology and capabilities of the social networks.

Interestingly, social media compliance concerns can vary by department. For example, compliance staff is concerned about effective supervision of business communications. Marketing wants to know which messages are most used, which have the most feedback, and which have generated the most interest. Corporate Communication is interested in protecting the corporate image. Human Resources is interested in employee usage of social media including what they are saying and how much of corporate time are they using to say it.

With all of these questions in the industry, how should that need for clarity be resolved?

Working with more than 100 firms for more than two years on these challenges, we are well aware of these concerns but also the growing examples of firms that are successfully using social business techniques and practices to grow their business.  In order to help bridge the industry and regulation divide, we recently hosted, with LIMRA,  the Regulator Roundtable on Social Media in Washington, D.C. Joined by attendees from seven regulatory agencies and four industry associations, we had a lively conversation about the unique dynamic for social media in the financial services market.

At the roundtable, we shared the concerns that came directly from industry firms.  We discussed how those concerns mapped to the objectives of the regulators.  We covered specific topics like privacy, security, policy and supervision in order to find that middle ground of effective but also compliant social media usage.  The roundtable discussion was well received by all, and we plan to have an ongoing dialog on the topic.

Are you looking for answers for how to ensure compliant and successful social business programs for your organization?  Contact us directly to learn more about how your firm can respond to the compliance challenges in order to realize the business opportunities in social.