- Recordkeeping – The obligations of a firm to keep records of communications made through social media depend on whether the content of the communication constitutes a business communication.
- Supervision – NASD Rule 3010 requires each firm to establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable federal securities laws and FINRA rules.
- Links to third-party sites – A firm should not include a link on its website if there are any red flags that indicate the linked site contains false or misleading content. Additionally, a firm is responsible under NASD Rule 2210 for content on a linked third- party site if the firm has adopted or has become entangled with its content.
- Data feeds – Firms must adopt procedures to manage data feeds into their own websites. Firms must be familiar with the proficiency of the vendor of the data and its ability to provide data that is accurate as of the time it is presented on the firm’s website.