Happy you found this FINRA 10-06 webinar summary useful. From my reading on the regulation as well as the webinar, FINRA defines “real time interaction” the same way they define a public appearance. It would be a chat room or online seminar where the dialogue can be considered unscripted and two way. This blog would likely be considered “static” under the FINRA regulations.

Additionally, since I stated that I was happy you found this summary useful, I would have been considered to have “endorsed” your position which is not is not allowed… that is unless I had my reply pre-approved by the Legal department.

Talk about confusing!

Still confused about blogs though. What does “REal time interaction” really mean? Is that a chat room, or is that refering to comments like the one I am leaving now. In other words, If this blog was subject to FINRA, would it be considered “Static” or a “Public Apppearance”?

Glad you found the article helpful. In regards to social networking sites may enable communications from Rep-to-Rep or Rep-to-Broker/Dealer, FINRA provided the example of some of the instant messaging platforms such as the functionality built into a Bloomberg terminal or a Thomson Reuters Trade Station. FINRA was very clear that those communications are between certified institutional participants and is therefore not covered by 10-06 and interactive social media communications.

Do you have a reference for me on point 5 bullet 3? I agree with your assessment, but there seems to be some confusion out there in the compliance community that the new social media retention/monitoring requirements (10-06) also applying to peer to peer/professional to professional collaboration applications that are closed to the public. Do you have a reference you could share with me on this?

Thanks for providing the great information on social media, it will be very useful for all visitors.