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FINRA Regulatory Notice 10-06: For Compliance Guidance Only
Inbound Marketing, Revenue GrowthEvery day there is an article like this one in a local newspaper sympathizing with someone who was fired because of something they posed online. Thankfully for registered representatives, FINRA is catching up with the digital age and addressed the issue of regulation and social media, fittingly, on its blog. In early January 2010 it released Regulatory Notice 10-06 which is intended to serve as guidance for Registered Representatives. Though short by FINRA standards at only ten pages, it is as monotonous as other FINRA publications. But true to form it does spell out some key things to keep in mind when using social tools:
Record Keeping
Because Twitter, Facebook and any of the other numerous social networking tools are written communication, the correspondences must be retained if they relate to “business as such.” The content of the particular post governs if it falls under the record keeping regulation or not. There are tools from Arkovi and Socialware that help address this.
Suitability
The same FINRA rules apply to social media as every other communication with customers. FINRA suggests going in two different directions with maintaining Suitability compliance. You may either a) make recommendations but only let suitable customers see them or b) don’t make recommendations. Make sure that either your settings or comments are restrained enough to not allow a recommendation to be seen by the wrong person.
Static
Blogs, being a static environment, are considered advertising and must be approved by a regulatory principal. This means that both Suitability and Record Keeping regulations apply.
Interactive
Unlike other the social communications mentioned above, posting on Forums is considered a public appearance and is regulated by the same Rule (2210) that would govern any event you were at in person. The same standard applies to the comment areas of blogs, Facebook walls and other areas with interactive ability.
Facebook
Facebook content falls under both of the two categories listed above. The Profile, pictures, banner ads and any content that users can’t interact with is considered static and must be approved by an appropriate regulatory principal. The wall, comments and any other content that non-firm employees can comment on, poke or engage in some activity is considered interactive. This means that a regulatory principal does not need to approve communications before posting. Due to an employee posting, well, anything on their employer’s wall could be construed as advertising it is not advisable to post non-approved principal approved comments.
As illuminating as this publication was, it is still merely guidance which FINRA offered to shed some light on these key issues. With social media and all other communication tools – Hello, Reply All button – common sense will protect will protect you more often and fully than any compliance officer ever can.
Stay tuned for more articles addressing platform specific concerns.
Too Social?
Revenue Growth, Social MediaI gave up Facebook for Lent. The funny thing is, I’m Buddhist. Well, raised Buddhist. Anyways, as I was trying to get my kids to eat their dinner, I was on Facebook reading about what my friends were feeding their kids. It suddenly occurred to me that I had been spending too much time there and needed to prioritize. So, I instantly deactivated my account.
I felt completely liberated the first day without Facebook. I was free of the need to come up with witty status updates, free of the ‘obligation’ to share good information, free of the curiosity of what my friends were up to.
The second day, I still didn’t miss my friends. I missed the information I get from the pages I “like.” I never realized that Facebook had been my primary source for the news and topics I cared about. Right after I deactivated my account, I read an article that Facebook was now the biggest news organization in the world. Great. I gave up Facebook for Lent and won’t be signing in again until Easter. What was I to do?
I turned to my Twitter account. It had been a while, since Facebook was all I “had time for.”
Immediately, I was overwhelmed by the many 140 character bits of information from the 89 people, companies, groups that I had initially started following. Was I following too many or were too many Tweeting too much? I cared about all of them, but who do I stop following?
John Stone wrote, “think quality versus quantity” when it comes to blogs. Truly, the same applies to Twitter, Facebook, and other social media sites. Especially for business and organizations, the quality of the posts and the information shared needs to be thoughtful and valuable to maintain the interest and keep the trust of their followers. Too much information creates follower fatigue. That’s what happened to me on Facebook. In one day, I was beginning to happen with Twitter.
I like my news. I like getting them via social sites. We advise our clients to value an editorial perspective and a careful selection of relevant posts. I hope the companies and groups I follow on Facebook and Twitter do the same.
Participatory Marketing and Audience Engagement
Content Marketing, Revenue GrowthThis blog has discussed various aspects of Permission Marketing at (see here or here) however there has been a recent trend of Participatory or “opt-in” marketing. This post explains a few techniques that two firms (with very different products) are using. Both of these companies have fulfilled five of the steps we outlined previously to generate prospective clients and along the way used several key attributes required in a participatory community:
1. Low Barrier to Entry
2. Support for creating and sharing ideas
3. Informal Mentorship
4. Participants feel their contributions matter
5. Participants engage in a community
These two particular companies are being exemplified because they both fulfill the requirements of inbound content: Entertain and Educate.
E*Trade Babymail: Entertain
The E*Trade baby has reached meme status after his debut during Super Bowl XLII and has been parodied by a few comedy talk shows and a headlining sit-com. In addition to this year’s Super Bowl Ad, the E*Trade baby has also been launched in a write-your-own-skit via www.etradebabymail.com. The website allows visitors to create their own talking baby segments which, naturally depending on the comedic prowess of the user, can be hilarious. While the actual use of the tool has nothing to do with E*Trade’s core business, website and email of the clip sent to the user’s friends is peppered with implicit advertising.
More importantly, E*Trade’s main marketing vehicle becomes participatory. The simplicity of the website all but removes the barrier of entry for the user both to the tool and the brand. The dual effect of this is to increase civic engagement and provide strong support for creating and sharing the creations with others. The first increases brand engagement while the second increased brand exposure to the user’s friends. E*Trade has provided the tool to create a participatory culture which shifts the focus from individual expression and consumption to community involvement.
Zacks Investment Research: Educate
The day after initiating coverage of Trius Therapeutics (TSRX), Zacks Investment Research published an article on SeekingAlpha.com explaining the analysis behind the firm’s initiation of coverage with an outperform rating. The forum is as important as the content for this example.
Seeking Alpha self-describes as “the premier website for actionable stock market opinion and analysis, and vibrant, intelligent finance discussion.” The model of the website is simple: Unpaid authors contribute, editors cull, readers read and the platform collects revenues from advertising. An important structural feature of the website is that it is made clear that anyone can submit an article for publication. This enables participation of members who believe that their contributions matter and who feel some degree of social connection with each other. Zacks released their report on this particular website because of the single biggest thing they and Seeking Alpha have in common is audience: individual investors looking to for an edge.
Zacks’ poster, Jason Napodano, comments on his own article first – with an offer of the 20 page Initiation Report for free (!) if you email him. He also provides thoughtful responses to the community’s questions and critiques. The entire dialogue is available for public consumption and comment.
Conclusion
Reviewing the points we outlined in our discussion of constructive content marketing, both of these firms selected their vehicles and content to be relevant, integrated, aligned, “peanut butter” (sticky and spreadable) and – most importantly – free. Let’s run through the list of attributes (and their manifestations) that a healthy participatory community has once again:
1. Low Barrier to Entry – Free internet sites
2. Support for creating and sharing ideas – The tool to create a presentation or post a comment
3. Informal Mentorship – Watch other user’s clips and forum postings
4. Participants feel their contributions matter, or at least are seen – See above
5. Participants engage in a community and therefore create a social connection – The Result
It is useful to note the specificity of both advertising methods: A Super Bowl ad exposes about as broad a spectrum of possible clients as a single thirty second spot can get while posting a (what is normally paid content) article on a website for readers with specific interest exposes a narrow band of possible consumers. These are two very different methods, both in audience and cost, to produce audience engagement. Both of these cases have the requisite value exchange for this Permission marketing to be consumed, enjoyed and passed along.
Don't Let the Fruit (of Your Marketing Efforts) Die on the Vine
Inbound Marketing, Revenue GrowthWhile companies ramp up their inbound marketing campaigns, something is happening to their house lists… they are getting tired. Naturally, hot leads find their way to sales. The rest of the new warm leads need nurturing, so they don’t die on the vine. Sending message after message may not get those warm leads any hotter. Unless those messages are targeted, relevant, and timely, companies are only exhausting their lists. The audience loses interest. Now, that’s rotten!
So, what are we left to do?
Continuing inbound marketing campaigns to keep feeding the database with new leads is an option. Augmenting the lists with third-party information to build a fuller profile, is another option. Analyzing customer lists, creating segmentation and a scoring system can help one gain a better understanding of customer’s needs. That is an option too.
No one, especially those in the B2B space, wants to see potentially good lead die on the vine. Sales people don’t want to waste their time calling cold or unqualified leads. Capturing leads, getting as much information as you can to build a profile, and segmenting them into groups is the first step to nurturing leads. Using the customer analysis, one can create targeted relevant messages to re-energize interest. This is the second part of the equation to keeping leads healthy. These tactics help marketers care and nurture healthy leads until they’re ripe sales opportunities.
MIT Sloan Sales Lecture
Revenue GrowthI have been invited to speak as a guest lecturer at the MIT Sloan Sales Club on February 23 and when considering the right focus for the session, an important sales transformation issue came top of mind.
Call it sales 2.0 perhaps, but the real transformation has come from the intense competitive challenge and the need for a differentiated relationship process.
Today’s sales teams clearly can no longer work through the phone book or the local business journal lists to find the target buyer. Today, sales managers must put together a far more integrated demand generation program and team up with marketing to make it happen.
In the session, I will explore the new dynamics of sales in today’s digital context. I will explore selling from the lens of the sales manager who must now orchestrate an integrated sales engine from demand generation and lead nurture to sales excellence and account management. In today’s environment, a fully aligned sales and marketing capability and integrated multi-touch campaigns are critical and sales must embrace new technology, content marketing and persuasive communications to meet targets.
Your Blog: Quality over Quantity
Content Marketing, Revenue Growth, Social MediaIn the age of information overload, the quality of your blog content matters more than ever. While there’s a temptation to flood the internet with frequent blog posts, focusing on creating high-quality, valuable content can have a more significant impact on your audience and your business goals.
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