According to the SEC update: "Investment advisers that use or permit the use of social media by their representatives, solicitors and/or third parties should consider periodically evaluating the effectiveness of their compliance program as it relates to social media. Factors that might be considered include usage guidelines, content standards, sufficient monitoring, approval of content, training, etc. Particular attention should be paid to third party content (if permitted) and recordkeeping responsibilities."
Prior to starting any actitivities online it is critical to prepare a detailed Social Media Policy and provide proper training and guidelines to all Advisers using the tools online.