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 It has been over 40 years since significant changes to "The Investment Advisers Act" were adopted. To say that advisors are excited about this recent update is definitely an understatement. With all of the different communication and social media platforms available to advisors, they are eagerly looking forward to sharing testimonials with potential clients hoping to open new doors of opportunities.
Firms and their compliance departments need to take a proactive approach when it comes to addressing these new marketing updates. Testimonials and endorsements still need to be monitored and approved to ensure they are not misleading investors. Firms need to decide what types of statements they are going to approve, what platforms will be utilized, and how registered advisors are going to notify them and gain approval before any endorsement is published. Initially advisors will want to add these testimonials and endorsements to their websites and other online destinations that may or may not be monitored by compliance. Demands on compliance’s time for monitoring and approvals will certainly increase. Additionally, firms need to reevaluate their disclosure policies to ensure that advisors provide notification and documentation of what and where they wish to publish testimonials and endorsements online. Compliance departments should expect to see a large increase in their workload related to internet monitoring and approvals that need to occur. What will compliance do to monitor endorsement and testimonial platforms such as Yelp, Google Reviews, or social media platforms like Linkedin, Facebook, and Twitter? Advertisements that include third-party ratings will be required to include specific disclosures to prevent them from being misleading. Is compliance waiting for advisors to disclose everything? Are policies based entirely on the honor system? How do you discover your advisor’s online presence, including these new testimonials and endorsements if they are not disclosing them to compliance? While you are forming your compliance strategy and updating policies, procedures and workflows it is important to consider how and what technologies can assist compliance with this increased workload. As the SEC and FINRA are adapting to new technology, compliance departments need to evolve and rely on innovative technology as well to support their job requirements. For over a decade, SiteQuest Compliance has continued to be a trusted partner, supporting compliance and supervision departments with tools that can help meet these increasing demands with regards to compliance and supervision. Our Eagle Eye solution uncovers and supervises your advisors’ online footprint. It discovers social media accounts, websites, blogs, yelp pages, OBAs, DBAs, and online profiles, allowing you to address issues prior to regulatory discovery or examination. Our SQWatcher platform monitors and archives advisor websites including those that may be hosted by non-approved website providers. It creates historical records of these sites, creates workflow events of specific types of changes like new pages, changes to readable text, images, and more with customizable rules to meet your needs. This update to the Investment Advisers Act will require your firm to revise its policies. Our newly launched Policies solution is a powerful tool used to organize, version control, and distribute your firm’s policies and Written Supervisory Procedures (WSPs) to your employees and advisors. Ensuring that your advisors always have access to your most current policies with easy to search features. As your advisors are “Modernizing their Marketing Practices” contact us today to discuss your specific needs and concerns. Let us show you how we can help streamline your workflows to maximize your time, while helping to ensure you don’t miss anything with regards to internet and website supervision and content approval. Sources: https://www.sec.gov/news/press-release/2020-334 | https://www.sec.gov/rules/final/2020/ia-5653.pdf  Whether they wanted to innovate, or a pandemic forced their hand, advisors embraced more digital marketing resources during 2020.
According to InvestmentNews Research, 42% of advisers have used a new digital marketing or technology tool for the first time during 2020, while 88% have expanded the use of at least one tool. The driving force, not surprisingly, was the pandemic, and a stay-at-home environment that forced advisors to find new ways to connect with their customers. As our world has changed over the past year it begs questions like:
Surges in online marketing and communications are not going to level out anytime soon. 80% of surveyed advisers said they would be placing more importance on their digital marketing in the coming year. For nearly a decade, Eagle Eye has provided a platform compliance can rely on when it comes to monitoring the internet activity of their advisors. Eagle Eye discovers social media accounts, websites, blogs, OBAs, DBAs, online profiles, and events that belong to or are about your advisors, allowing you to address issues prior to regulatory discovery or examination. Eagle Eye monitors 50,000+ advisors across our customer base and has automatically alerted compliance supervisors on over 1.2M discoveries that warranted reviews broken down by
Contact us to schedule a time to discuss your internet supervision compliance needs and concerns this New Year. We will show you the solutions that Eagle Eye provides to companies when it comes to internet supervision. Kindly, James Cella, President and CEO [email protected] Source: https://www.investmentnews.com/adapt-and-survive-2020-forces-adviser-embrace-of-digital-tools-199923  WHERE DID THE IDEA OF EAGLE EYE COME FROM?
We get asked this question all the time and honestly, we are proud to say that its genesis came from compliance and supervision professionals like you. In fact, many of the features and processes come directly from our clients and those who are using the application in short-term pilots. Learn More.  We would like to share with you some of the trends we are finding while assisting our clients with their requirements to supervise their representatives’ web presence:
The growth of the internet has been exponential over the last decade with no signs of slowing down. Hundreds of thousands of websites have emerged on every subject imaginable, with literally billions of web pages online. As of April, 2019, the Indexed Web is estimated to contain at least 5.6 billion pages, according to WorldWideWebSize.com. It is difficult to fully comprehend exactly how many websites and web pages there are out there in the vast internet universe. As a supervisor for a financial firm, you personally might have a better idea of how big it is when you are trying to supervise your representatives’ web presence. When performing a basic web search, you get hundreds, if not thousands of irrelevant results. It then becomes your job, as a supervisor to try and sift through all that web clutter to document and report on anything pertinent that you might find. It can end up taking most your day just trying to find results relevant to your intended search. Your time is valuable. Any search engine can produce an endless amount of meaningless results that need to be reviewed. Our Eagle Eye application is designed with built-in intelligence that sifts through the web’s clutter and brings only the most relevant results to your attention. Our multi-query processes and dynamically designed algorithms provide more accurate results for a quick review process. In addition to our search results our automated screenshots feature helps you document, report and escalate any issue that is brought to light. One of our clients said "The Eagle Eye Surveillance system has been a force multiplier in my firm’s supervisory scheme. This simple tool has transformed my internet surveillance sweep process from a time-consuming, multi-day enterprise where I view the same search results over and over to a simple process that can be completed in a couple of hours." Another one of our clients said: “As soon as we implemented Eagle Eye, the system found searches that were previously missed with the manual process and as a result, we updated our policy and procedures to minimize compliance risk. Also, one of our previous hurdles was demonstrating to our regulators with documentation that we were conducting the appropriate monitoring but with the audits reports, that are available directly from the system, we are able to document and show individual findings in an organized manner." Outside OBAs and unauthorized content from your representatives or advisors are a growing concern that will always be present. Minimize your risk by utilizing Eagle Eye. See for yourself how Eagle Eye will meticulously search the web for you and your firm.
Contact us today for a demo. Source: http://www.worldwidewebsize.com/  Are Yours? Do You Even Know It is Happening?
One website that is growing in popularity for advisors is Yelp.com. The ability to list your business and have people leave reviews is very tempting for advisors to use in hopes of gaining new clients. Unfortunately the use of Yelp is in direct violation of the SEC’s “Testimonial Rule” under the Investment Advisers Act of 1940. Recently, the Securities and Exchange Commission charged three advisers and a marketing firm for violating the testimonial rule by promoting their business on Yelp. These three advisors worked with a marketing company to solicit testimonials from clients asking them to post their reviews on the investment adviser's behalf to Yelp and other social media websites. Each of these advisors were fined $10,000. The marketing firm received cease-and-desist orders and were required to pay civil penalties of $35,000. YouTube is another platform that is rising in usage by advisors resulting in violations and fines. An Illinois-based RIA, was fined $15,000 for creating a 31-minute-long YouTube video that featured testimonials from multiple clients. The video was published on their public website and YouTube.com, and was shown to guests at a party celebrating the firm's 50th anniversary. This YouTube video was also in direct violation with the SEC’s “Testimonial Rule”. Are you actively monitoring Yelp and YouTube for these type of SEC infractions from your registered advisors? It can be difficult even knowing where to start. Over 4.6 million businesses are using Yelp. With an ever increasing 163 million Yelp reviews how are you to know if your advisors are actively soliciting testimonials from their clients? Adding to your monitoring struggle is YouTube. It is estimated that over 300 hours of video are uploaded to YouTube every minute! With over 1 billion daily users how are you to find videos uploaded to YouTube by your registered advisors if they don’t send you the direct links? Eagle Eye is a solution. With Eagle Eye precision our application will help you quickly identify any social media accounts including Yelp and YouTube that your registered advisors own. Allowing your firm to take action and comply with the SEC’s requirements. Eagle Eye’s automated documentation and screenshots of your findings will help you respond to a regulator. We’d love to show you more. Contact SiteQuest Compliance today to see how our application can aid in your supervision responsibilities, saving you time and lowering your risk. Related Article: Trends when it comes to supervising the web. Related Article: Known Compliance Gaps Sources: SEC.gov | Investment News  In a world of ever growing automation and computer work, it's easy to find yourself staring at your computer screen (or screens) virtually all day long. While sometimes we feel that our brains might be fried from such activities, you're eyes also pay a heavy price in the form of eye strain.
Here are some helpful hints on how to avoid eye strain based upon the 20-20-20 rule.
It also helps to adjust your computer display settings. Adjusting the brightness, text size, and contrast of your display can help reduce eye strain and fatigue. You'll find that by doing so, your focus on your work will increase while your eye strain symptoms will start to decrease. Give your eyes a break and let Eagle Eye do the work for you. Eagle Eye is a leading-edge application that automates your processes for searching, documenting, reporting and ultimately supervising your associates’ web presence. Many of our clients have found that using Eagle Eye can reduce their workload by as much as 80%. See how Eagle Eye can help save you time from having to stare at your computer screen all day. Contact us today!  FINRA recently sent out Regulatory Notice 20-30 regarding an increase in imposter advisor websites being created with malicious intent. These fraudsters are also calling and directing potential customers to use these imposter websites. Additionally these imposters may be using these sites to collect personal information from potential customers with the likely end goal of committing financial fraud. According to FINRA, some common features of these websites include:
FINRA suggests that “Member firms and registered representatives can take steps to identify these pages by conducting periodic web searches using registered representatives’ names.” The potential damage of an Imposter Website could be irreversible. What can you do?
Eagle Eye by SiteQuest Compliance has everything you need to monitor the internet and discover imposter sites and other compliance threats to your firm. Our multi-query processes, lexicon searches and dynamically designed algorithms provides more accurate search results saving you time and automatically alerting you to new search results concerning your registered representatives’ identity. Additionally, our system considers the domain name as it searches for results and scores them for potential reviews. Our easy-to-use workflows allow you to quickly review dozens to hundreds of search results in minutes. Many of our clients have found that with Eagle Eye they cut their workload by 80%. If you do discover an imposter website contact FINRA and the FBI immediately. See for yourself how Eagle Eye will support your compliance and supervision programs to monitor the web and discover these types of issues and more. Contact us today for your personalized demo. Eagle Eye also supports your firm’s adherence to regulatory requirements like FINRA Rules 2210, 3110, 3120, and 3270 by providing supervision of the internet. Read the Entire Regulatory Notice 20-30  Let’s face it, the coronavirus pandemic has fundamentally changed the way we do business. Most of our industry is working from home, learning to balance conference calls and kids with questions that just can’t wait or dogs that must bark while on a Zoom meeting. We’ve all been there and have our moments.
Other things have changed as well, especially when it comes to marketing and advertising. This is especially true for financial advisors who have lost the ability to connect with clients at events, lunches, in office or at home meetings or simple introductions that come from face-to-face interactions. or years, many advisor’s businesses have primarily depended on these methods to connect with current clients and meet new prospects. Social distancing and stay at home orders have eliminated these options for many advisors who are now exploring new options to prospect and connect with people. So where are they turning? Like everyone else, advisors are turning to technology to increase their online presence with updated profiles while sharing fresh and timely content. I recently spoke to some of our clients about trends they were seeing regarding their advisor’s marketing and advertising behaviors since social distancing and stay home orders began. One compliance manager told me his firm has seen a 30% increase in advertising submissions as well as a significant increase in the use of approved social media sites like Facebook, LinkedIn and Twitter. Another client told me, “Advisors have ‘downtime’ and are now thinking a lot about marketing.” I followed up on how things have changed for our client as a result. “Don’t get me started on how much social media usage has jumped since this all began!” They have seen an increase of 25% to 30% in usage and a surge in new accounts being created by their advisors. Social Media usage is certainly on the rise. A recent survey showed that 32% of Americans said they have increased the amount of time they are using social media sites like Facebook and Twitter. Another firm told me that advisors who have typically shied away from social media, online profiles, websites, and other marketing technologies are now diving in for the first time. I was told, “Their (advisors) traditional lead generation tools aren’t available anymore. They now have time and are focusing on new ways to build their business.” Additionally, our clients are seeing a big increase in advertising submissions for recordings from Zoom/online meetings. Advisors are continually seeking guidance on additional options for communicating and marketing to the public. This all presents an increasing challenge in supervision and compliance, especially when there are growing limitations on human resources. That’s where our Eagle Eye technology comes in. Eagle Eye helps our clients uncover their advisors’ web presence, locating social media accounts, websites, articles, profiles, videos, OBA’s and more. Eagle Eye creates automated documentation of what has been reviewed, who did the review, and what the website looked like at the time of review, giving our clients and regulators a complete picture of the process. They use our system to discover and “clean up” situations where the use of these sites was done without approvals or monitoring in place. Another one of our clients shared with us that, “Thanks to Eagle Eye, it is helping me identify and address issues before they are brought to my attention by a regulator.” With our industry evolving, SiteQuest Compliance is a preferred partner when it comes to internet supervision and website management. Contact us today for your personalized demo where we can discuss your supervision concerns and see for yourself how Eagle Eye can support your internet supervision requirements.  This spring FINRA announced the formation of the Office of Financial Innovation that will serve as a central point of coordination for issues related to financial innovations by FINRA member firms, particularly new uses of financial technology.
The goal in mind to further enhance FINRA’s ability to identify, understand and foster financial innovation in a manner that strengthens investor protection and market integrity. With 10 years of experience supporting our partners in their supervision and compliance with FINRA, SiteQuest Compliance is pleased about the dedication to financial innovation. SiteQuest Compliance has a long standing tradition of being a thought-leader. Working side-by-side with customers as we develop and improve our supervision applications to meet their needs. As more and more regulation burden is being put upon financial firms, SiteQuest Compliance is stepping up and serving as a trusted partner. Learn more about our applications. Eagle Eye is the first of its kind application that uncovers and supervises your advisors’ online footprint. It discovers social media accounts, websites, blogs, OBAs, DBAs, online profiles, and events that belong to or are about your advisors, allowing you to address issues prior to regulatory discovery or examination. SQWatcher stands for our SiteQuest "Watcher". Our SQWatcher application monitors and archives advisor websites that may be hosted by non-approved website providers. It creates historical records of these sites, creates workflow events of specific types of changes like new pages, changes to readable text, images, and more with customizable rules to meet your needs. Policies organizes, manages and delivers your firms policies and WSPs. Our Policies application provides a clean, easy-to-use, easy-to-search and up-to-date experience for your advisors. Policies brings all of your procedures, policies, WSPs and other documentation into one place that can be accessed on both a desktop and mobile devices. Our customers have referred to our applications as “force multipliers” that exponentially expand their search and supervision capabilities. Firms are able to identify and address issues before they are brought to their attention by a regulator. “Innovation continues to pose new opportunities and challenges for our member firms and the broader financial services industry, and it is essential that we as regulators keep pace,” said FINRA President and CEO Robert W. Cook. With the even increasing trend for registered advisors to utilize technology to grow their online presence with updated profiles while sharing fresh and timely content. It is paramount that supervisors have support and a partner to help them with their ever increasing responsibilities. Let us show you how we can help. Contact us today to discuss your supervision challenges. Together we can lay out a plan to keep pace with technology innovations. Source: https://www.finra.org/media-center/news-releases/2019/finra-forms-office-financial-innovation-announces-haimera-workie-head 4/20/2020
AUTOMATED SUPERVISION: HOW ONE FIRM UNCOVERED COMPLIANCE RISKS THAT WERE PREVIOUSLY UNDETECTED We often speak with firms that use search engines like Bing and Google to assist them with the manual supervision processes.
One such firm recently added Eagle Eye to their supervision processes and quickly discovered immediate returns on their investment within the first three months of its use. What was that immediate benefit? Reduction of risk. Now that wasn’t the only benefit, as they saved a lot time as they went through the process. In fact, prior to using Eagle Eye they would often struggle to complete their supervision checks before the end of the quarter and would have to rush during the last two weeks of the period to get it all done. With Eagle Eye, they finished everything with three or four weeks to spare. But back to our original point, how did they reduce their risk? Our client not only found the process easy, but more importantly, they uncovered previously unknown compliance risks that were routinely missed by their manual search processes. Their new set up with Eagle Eye allowed them to scan the web in a manner unlike any they had previously experienced. With Eagle Eye’s multi-data point scanning capabilities, this client unleashed a virtual army of web crawlers who scoured the web with dozens and dozens of powerful queries. Then Eagle Eye analyzed all of the possible results for each monitored individual and presented the most relevant findings for their review. Our client not only found the process easy, but more importantly, they uncovered previously unknown compliance risks that were routinely missed by their manual search processes. With the revelations of these new regulator risks, our client was able take immediate action and take care of the issue prior to a regulatory event. The astounding part of the story is that our client was able to accomplish all of this without having to review hundreds and hundreds of results for each monitored individual or firm. In fact, they were able to do so by reviewing just 20 results per monitored individual during their quarterly review. So the big question looms, what are you missing on your manual searches and can you continue to allow those risks to go unnoticed and unchecked? |
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