As
technology continues to proliferate our lives, it is important to understand
that all electronic communication being used for business related purposes must
be archived. As clients (and internal staff) continue to lean more heavily on
SMS text messaging and other electronic communication means, you as the Advisor
need to understand what your various options are to stay compliant.
What
types of communication have to be archived?
Any
written communication used for business-related purposes must be archived. This
does include internal communication within the office.
Team/Internal
Chat: If you are
using Teams or another chat system to communicate with each other across remote
locations or even within the same office, those communications must be archived
and reviewed.
Text
Messaging: If you
want to be able to actively text with clients, you must make sure that you are
using a text service that can be archived properly through our system. We do understand that you cannot stop clients
from texting you. However, you can control your responses to those SMS
messages. If text messaging is not being properly archived, you should respond
to clients that you cannot use SMS text messaging and/or contact them through
an approved communication channel. If you want to be able to freely text
clients, then you need to review some of the approved text messaging solutions.
NOTE: Every archiving solution does
have an archiving cost associated with it that will be passed through to you;
these costs are in addition to any subscription costs to the service itself.
What
about video conferencing?
Video
conferencing does not have to be archived. However, if the video archiving has
a chat functionality that is made available during meetings with clients or
prospects, then the chat functionality must be archived. Otherwise, you should
ensure that the chat functionality is turned off for these video conference
meetings.
Approved
Electronic Communication Solutions
|
System
|
Archiving
Cost
|
Notes
|
|
MyRepChat
|
$10/month/user
|
SMS
capable; can add texting to a line that does not have texting
|
|
RedTail
Speak
|
$6/month/user
|
SMS
capable; requires opt-in from recipients
|
|
CellTrust
|
$10/month/user
+ $400 one-time setup (minimum 10 users)
|
SMS
capable; must pay for 10 users
|
|
Teams
|
$6/month/user
|
Not SMS
capable; chat authorized for internal use; video conference approved for
external use
|
Additional
Information
Additional information on our policies can be found on the
Power Portal Knowledgebase.
If you have questions about this
guidance or any particular scenario, please reach out to Compliance to schedule
time with us.
Thank you,
The Mutual Compliance Team
