Getting Started on Twitter for Investment Marketers: Dealing with Risk

Take one of the world’s most regulated industries, add in understandably zealous compliance teams, mix with a freewheeling, instantaneous communications platform, and what do you have?

If you answered “an unholy mess” or somesuch, you’re almost certainly not alone. But compliance is no longer the show-stopper it once was for financial marketers looking to use Twitter. Following the FCA’s recent consultative paper on social media use, there is a growing recognition that a flexible approach is both legitimate and necessary in dealing with social media communications.

While the FCA’s paper was aimed at social media more generally, much of it focused on problems specific to limited-character platforms, and particularly Twitter. Clearly, a medium limited to 140 characters is not the ideal place to enter into extended disclaimers – a problem highlighted by a financial PR I spoke to who railed against a compliance directive that all Tweets should contain the words “past performance is no guarantee of future success.”

While acknowledging that social media is now a fact of life for finance marketing, the FCA guidelines actually indicated that Twitter is unlikely to be the ideal platform for financial promotions. This is partly because any communications that qualify as promotions will be subject to existing requirements for ads, namely that they be “fair, clear and not misleading”, and that risks are stated up front. One way of partly addressing these requirements, the guidelines said, is through the use of the hashtag #ad:

risk compliance fca #ad

Another possible way around the character restriction, the FCA suggests, is by the use of infographics, which provide far more room to include disclaimers:

risk compliance fca #ad 2


Nonetheless, even this is not a panacea, as the FCA notes:

“We are aware that the functionality that allows a Twitter image to be permanently visible may be switched off so that the image appears simply as a link. Therefore, where the financial promotion triggers a risk warning or other information required by our rules, this cannot appear solely in the image.”

All this prompts the question, if the constraints are so tight on what can be said, is Twitter really the right platform for investment marketers at all?

To answer this, it behoves us to return to the question of, Why get involved in social media in the first place? Volumes have been written about how social media represents a break from traditional marketing, in that it places central emphasis on the “conversation” rather than a one-way broadcast. But there is evidence that perhaps the most consumer-facing of financial institutions, retail banks, are not getting that message:


Thus, if your broader social media goal is raising brand awareness or building trust, employing conventional promotional messages in Tweets may not be the best way to achieve that. To repeat, social media and Twitter’s great strength is not as an ad platform, but as a forum for engaging with and fostering trust among prospective clients (and this, of course, should also be in service of a broader marketing strategy).

This is not empty theorising. Look at the Twitter feeds of all the key asset-management houses and you will see few if any Tweets promoting funds or services. The overwhelming aim of these feeds is establishing an asset manager’s credentials as a “thought leader”, building brand awareness or, in some cases, prompting debate and responding to questions.

In these circumstances, what specifically should marketers keep in mind when preparing to Tweet?

  • Oversight: Establish a clear but appropriately light-touch approach to oversight. The tension underlying many companies’ social media efforts – immediacy versus compliance – is exacerbated on Twitter, thanks both to its spontaneity and constraints on space. An FT piece from last year noted the extremes this conflict could take, mentioning a financial firm that required no fewer than eight levels of sign off for Tweets. However, Tweeting by committee not only makes it very difficult to respond quickly, it also, as PwC has noted, leads to very stiff, corporate-sounding posts – precisely the kind of language likely to make readers bored and cynical. Thus, while it is essential to have proper oversight, the most effective approach is perhaps to reach a happy medium – establish guidelines, ensure the relevant staff are well versed in them, then have compliance ensure those guidelines are being met, rather than insist on individual sign-off on every single Tweet.
  • Archiving: As with all social media efforts, and, indeed, financial communications in general, a thorough and effective method of archiving is essential. Happily, some tailor-made tools already exist for this, including Hootsuite, Arkovi and Erado.
  • Monitoring: If you’ve ever complained about a large company online, you’ll notice how quickly they respond with an apology and an offer to take the complaint “offline”. One of Twitter’s great strengths is its ability to allow marketers to keep a close eye on what is being said about their company. This can also help with keeping on top of any potential issues arising from poorly worded or misinterpreted Tweets. Robust existing tools for this include Hootsuite, Tweetdeck and Brandwatch.
  • Ownership: For a company-branded account, this should be fairly straightforward. Social media posts, accounts and followers will remain under the ownership of the company, irrespective of the individual in charge. However, as PwC notes, complications could arise if employees within a financial firm have a blog or issue Tweets under their own name. If that person joins another company, what then? Are the potentially thousands of followers, probably including clients, then automatically transferred with that fund manager? Or does he have to build them up again from scratch? Clear rules for this should be established in advance.
  • Content: In general, it makes sense to speak as an expert, not as a salesman. Share your company’s research, offer opinions on economic trends and talk about what’s happening in your sector. Don’t recommend specific stocks and avoid promoting your firm’s products. Not only does this approach avoid a host of regulatory headaches, it’s far more likely to be of interest to your followers.
  • Training: Don’t just come up with Twitter guidelines – ensure the relevant staff actually know and understand them. Have regular updates to address concerns and make sure that everyone is on board and understands their scope and responsibilities.

This list is by no means exhaustive, nor does it offer any guarantees. But along with the specific requirements of your company and its broader marketing strategy, they will help ensure that Twitter can be used as the hugely powerful marketing tool it is. Should you want to chat further about your social media requirements, feel free to drop us a line.