Twitter, Facebook and LinkedIn are currently the only approved social media sites that can be used for business purposes.
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1 Social media outlets offer an effective way to increase existing client touches and prospect for new clients. This training document explains the requirements you must satisfy prior to using approved social media sites for business purposes. Approved Social Media Sites Twitter, Facebook and LinkedIn are currently the only approved social media sites that can be used for business purposes. Are Personal Social Media Accounts Subject to these Requirements? You may have unmonitored personal social media accounts as long as the only reference to your work is the name of your firm and your title. References to promote your business on a personal account would turn your personal site into a business related site subject to monitoring and retention. Examples of these promotional references include: Listing your business website Discussing financial products Posting about financial related services you offer Discussing your own business persona Social Media Requirements Follow the steps below prior to using approved social media outlets for business purposes. If you are an RIA only firm that has no relationship with Cetera Advisor Networks you only need to complete steps 2, 3, 5, and 6. Page 1
2 1. Complete Cetera Social Media Training Cetera requires that you complete a training course prior to using social media sites for business purposes. Access this course within SmartWorks as explained below: 1. Login to SmartWorks at 2. Select "SmartWorks Learning Center" from the "Training" drop down menu. 3. Select "Stay Compliant" on the left side of the page. 4. Click to access the course titled "Social Media Compliance Training". Once the required training is completed, you will receive an confirmation with next steps including how to register your accounts with the Cetera Social Media Supervision Tool (formerly C2C Social) referenced in step 4 of this process. Please Note: The Cetera course inaccurately references the need for pre-review of all social media posts in Cetera's Social Media Supervision Tool. This requirement only comes into play for Carson Institutional Alliance advisors if your post references specific securities or products. Page 2
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4 2. Create Accounts on Social Media Sites If necessary, open social media accounts on the sites you plan to utilize for business purposes. Use the links below for instructions on how to create accounts on the approved social media outlets. Creating a Business Page on Facebook Creating a Business Profile on Twitter Creating a Company LinkedIn Account If you have a LinkedIn account that is used as a static online business profile and do not plan to interact in any way on this page (submitting posts and pictures, commenting and liking posts in the feed or within group), then you are not required to have your LinkedIn account monitored by the Social Media Supervision Tool. Please be sure to obtain approval of your static profile from Ad Review Page 4
5 through your standard submission process, and include a screen capture of your page when submitting. 3. Add or Update Disclosures on Social Media Sites Add or update required disclosures and references on your social media profiles to reflect CWM, LLC's relationship with Cetera. Required disclosures for partner firms affiliated with Cetera and RIA only partner firms can be found at the end of this document. 4. Register Social Media Accounts with Cetera's Social Media Supervision Tool You are required to register your social media accounts with Cetera's Social Media Supervision Tool which allows Cetera to review your social media activity. Follow the steps below to access the Social Media Supervision Tool page to learn more and register your social media accounts. 1. Login to SmartWorks at 2. Select "Social Media Supervision" from the "Quick Links" drop down menu. 3. Click the "More Information" link under "Getting Started". 4. Click to open "Step 4" for information about registering your social media accounts. Page 5
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8 5. Submit Your Profiles to CWM Compliance for Review Submit your social media profile(s) in PDF format for review through a Compliance Approval case in the C.E.O. system. Click here to learn more about the Advertising Submission process. 6. Register Your Social Media Accounts with Erado You are required to register your social media accounts with Erado which allows CWM Compliance to monitor and review your social media activity. If you work with one of our Foundational Partner offices you can contact them directly for assistance. Otherwise, please the CIA Compliance team at compliance@carsoninstitutional.com to facilitate this step. Page 8
9 Disclosures For Partner Firms Affiliated with Cetera 1. Facebook Disclosure Copy and paste the applicable disclosure in the Impressum section of your Facebook business page. After saving, be sure the FINRA and SIPC hyperlinks function correctly. Non-California Insurance Licensed Securities offered through Cetera Advisor Networks LLC, Member FINRA/SIPC ( and Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Cetera Advisor Networks LLC is under separate ownership from any other named entity. Third party posts found on this profile do not reflect the views of Cetera Advisor Networks or CWM, LLC and have not been reviewed by Cetera Advisor Networks or CWM, LLC as to accuracy or completeness. CA Insurance Licensed Securities offered through Cetera Advisor Networks LLC (doing insurance business in CA as CFGAN Insurance Agency), Member FINRA/SIPC ( and Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Cetera Advisor Networks LLC is under separate ownership from any other named entity. Third party posts found on this profile do not reflect the views of Cetera Advisor Networks or CWM, LLC and have not been reviewed by Cetera Advisor Networks or CWM, LLC as to accuracy or completeness. <<if for individual advisor social media page the disclosure needs to include: California Insurance Producer License Number <<123456>>. 2. LinkedIn Disclosure Copy and paste the applicable disclosure in the "Summary" section of your LinkedIn account. Non-California Insurance Licensed Securities offered through Cetera Advisor Networks LLC, Member FINRA/SIPC (For hyperlinks to FINRA and SIPC, please refer to 'Contact Info' section above). Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Cetera Advisor Networks LLC is under separate ownership from any other named entity. Third party posts found on this profile do not reflect the views of Cetera Advisor Networks or Page 9
10 CWM, LLC and have not been reviewed by Cetera Advisor Networks or CWM, LLC as to accuracy or completeness. CA Insurance Licensed Securities offered through Cetera Advisor Networks LLC (doing insurance business in CA as CFGAN Insurance Agency), Member FINRA/SIPC (For hyperlinks to FINRA and SIPC, please refer to 'Contact Info' section above). Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Cetera Advisor Networks LLC is under separate ownership from any other named entity. Third party posts found on this profile do not reflect the views of Cetera Advisor Networks or CWM, LLC and have not been reviewed by Cetera Advisor Networks or CWM, LLC as to accuracy or completeness. <<if for individual advisor social media page the disclosure needs to include: California Insurance Producer License Number <<123456>>. For LinkedIn you are also required to add hyperlinks to the FINRA and SIPC websites in the "Contact and Personal Info" section. After saving, be sure the FINRA and SIPC hyperlinks function correctly. Page 10
11 3. Twitter Disclosure Add the below disclosure to the "Bio" section of your Twitter business profile. Cetera Advisor Networks LLC, Member FINRA/SIPC. Advisory services offered through CWM, LLC, an SEC Registered Investment Advisor and separate entity. Disclosures for RIA Only Partner Firms 1. Facebook Disclousre Copy and paste the applicable disclosure in the Impressum section of your Facebook business page. Non-California Insurance Licensed Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Third party posts found on this profile do not reflect the views of CWM, LLC and have not been reviewed by CWM, LLC as to accuracy or completeness. CA Insurance Licensed Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Third party posts found on this profile do not reflect the views of CWM, LLC and have not been reviewed by CWM, LLC as to accuracy or completeness. <<if for individual advisor social media page the disclosure needs to include: California Insurance Producer License Number <<123456>>. 2. LinkedIn Disclosure Copy and paste the applicable disclosure in the "Summary" section of your LinkedIn account. Non-California Insurance Licensed Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Third party posts found on this profile do not reflect the views of CWM, LLC and have not been reviewed by CWM, LLC as to accuracy or completeness. CA Insurance Licensed Page 11
12 Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor. Third party posts found on this profile do not reflect the views of CWM, LLC and have not been reviewed by CWM, LLC as to accuracy or completeness. <<if for individual advisor social media page the disclosure needs to include: California Insurance Producer License Number <<123456>>. 3. Twitter Disclosure Add the below disclosure to the "Bio" section of your Twitter business profile. Advisory Services offered through CWM, LLC, an SEC Registered Investment Advisor. Page 12
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