Video
messaging, including video blogs (“vlogs”) are becoming increasingly popular
across all industries, including financial services. How we have to treat those
videos depends greatly on how you wish to use them. If you are wanting to
utilize video marketing through YouTube, it is important that you understand
our policies around its usage.
What
is the YouTube Usage policy?
This
policy applies to both Mutual Securities, Inc. and Mutual Advisors, LLC
(collectively “Mutual”) and applies to all Registered Representatives/Investment
Advisor Representatives and Licensed Admins (collectively “registered
persons”). It covers any video marketing conducted for business related
purposes or where you are holding yourself out as a financial professional.
All videos
are considered retail communication/advertising and must receive pre-approval
from Compliance. Beyond this, how you must treat each channel and video is
dependent on whether you choose to have your channel and videos archived
through our system. NOTE: every archiving solution does have an
archiving cost associated with it that will be passed through to you; this is
in addition to any subscription costs you may pay for the service itself.
Submission
of Videos for Review/Approval
Videos
may be submitted to Compliance via the Power Portal just like
any other retail communication/advertising. You will be required to provide a
link to the video which must remain in an “unlisted” status on YouTube with the
comments turned off until it is approved by Compliance. A copy of the .mp4 file
will also be required to be uploaded for our books and records. This copy can
be provided after the initial review is done by Compliance. Depending on
whether you choose to archive your channel or not determines what you are able
to do with the video after it has been approved.
NOTE: Best
practice is to upload a script to Compliance prior to recording, particularly
if you are unsure whether your content would be approved. This will prevent
potential additional editing in the event something needs to be changed to
remain compliant.
YouTube
Video Usage – Archiving vs No Archiving
The
biggest difference between archiving a YouTube channel and not archiving a
YouTube channel is the ability for comments to be turned on for both the
channel and videos, as well as for the videos to be put into a “public” status.
Public videos are able to be found online and offer some additional SEO
functionality for advisors. However, in order to be compliant with
public-facing videos, we must ensure that active monitoring and archiving is
being maintained over the video and the channel.
YouTube
Archiving Costs
Mutual
has two options available for archiving YouTube channels and videos.
Pagefreezer
|
Service
|
Cost
|
|
One-Time
Channel Set-up
|
$500
|
|
Monthly
Cost per Channel (with up to 50 videos)
|
$701
|
|
Monthly
Cost per Channel (with 51 to 100 videos)
|
$1401
|
|
Monthly
Cost per Channel (with 101 to 150 videos)
|
$2101
|
1 Pagefreezer is charged monthly but
is an annual commitment. If you choose to terminate your archiving prior to the
end of your 12 months, you will be subject to pay the remaining balance.
Smarsh
|
Service
|
Cost
|
|
One-Time
Channel Set-up
|
$1500
|
|
Monthly
Cost per VIDEO
|
$10
|
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
