This document discusses social media participation within broker-dealer environments. It outlines how Putnam Investments, an investment management firm with $133 billion in assets under management, actively participates in social media while balancing regulatory risk and reward. The document describes Putnam's process for oversight of social media content and participation to ensure compliance with broker-dealer regulations. It also notes developments like the emergence of LinkedIn as an important channel and the effectiveness of Twitter for engagement.
The CMO Survey - Highlights and Insights Report - Spring 2024
Social Media in Broker-Dealer Compliance
1. Social Media in a Broker-Dealer
Environment
Derek A. Stern
Assistant Director of Broker-Dealer Compliance
Putnam Investments
For investment professional use only. Not for public distribution.
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2. About Putnam Investments
• $133 billion in assets under management*
• Mutual funds, 401(k) plans, 529, IRA,
institutional, international
• Active in social media since 2009
As of 2/28/13.
For investment professional use only. Not for public distribution.
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3. A culture of innovation
For investment professional use only. Not for public distribution.
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4. Social media participation:
Weighing the risk and reward
Risk Reward
• Brand • Perception
• Regulatory • Reach
For investment professional use only. Not for public distribution.
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5. The social media sandbox
For investment professional use only. Not for public distribution.
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6. Broker/dealer oversight
For investment professional use only. Not for public distribution.
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7. Process: Broker/dealer static content
Traffic Compliance
database database
• Editorial Series 24
• Design
• Criteria
• Social media • Criteria
• Web development • Criteria
Compliance
database
For investment professional use only. Not for public distribution.
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8. Enterprise adoption, interactive content,
and developments
Enterprise adoption
• Moving compliant participation from one to many
Interactive content
• Moderation of selected interactive content related to product
• Moderation of selected interactive behavior by lexicon
• Post-review process
Developments
• LinkedIn emerging as important channel
• Twitter most effective channel for engagement
For investment professional use only. Not for public distribution.
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9. Thank you.
www.linkedin.com/in/derekstern
The views and opinions expressed are those of Derek Stern, are subject to change, and
are not meant as investment advice.
Consult with your firm’s compliance department and be fully aware of its policies and
procedures before you engage in any social media activities.
For investment professional use only. Not for public distribution.
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