Presented by: Cadaret Grant & Co., Inc.

1. Using Social Media Financial Advisor Tutorial Presented by: Cadaret Grant & Co., Inc.

2. Advisors who use Facebook, LinkedIn, or Twitter for business purposes are required to complete this social media training before using social media applications for business purposes. OSJ managers must complete this training, as well, in order to effectively supervise advisors who use these sites.

3. What is social media? • A Web-based application to communicate and share information with clients, prospects, and colleagues. • Cadaret, Grant currently supports the use of Facebook, LinkedIn, and Twitter. • Social media allows advisors to: • Stay in touch with clients. • Build a professional network. • Promote referrals. • Share information to attract new clients and keep current clients engaged and informed.

4. When is the use of social media subject to regulatory supervision? • When used for business purposes. • Contains information beyond listing your firm name or the type of work you do. • Within a personal profile, it is permissible to list your firm name or title when describing work experience or profession and still be considered personal use. • Additional information such as listing a firm web address, business contact information, or services offered are considered business use.

5. Business vs. Personal Listings • Keep business social media separate and distinct from personal social media. Personal profiles are used to share information with friends and family and are not business related. • Conceal personal accounts using privacy settings. • With the exception of LinkedIn, some social applications allow for a clear distinction between personal and business use. • LinkedIn is intended to be a business networking site, therefore LinkedIn profiles, regardless of the content, must be registered with Smarsh prior to posting.

6. Static vs. Interactive Content • Static content is defined as content that remains unchanged unless edited by the user. • Examples of static content include: • Biographical or contact information included in a profile. • Video posted to YouTube. • Business listing posted on sites such as YellowPages.com. • Blogs.

7. Static vs. Interactive Content • Interactive content is defined as real-time communications between two or more parties. Examples of interactive communications include: • Status updates on Facebook. • Share an update on LinkedIn. • Tweets on Twitter. • Business use of interactive social media sites other than Facebook, LinkedIn, and Twitter are currently prohibited.

8. Permitted and Restricted Activities when using Facebook, LinkedIn and Twitter

9. Requirements for business use of Facebook, LinkedIn, and Twitter • Review Social Media Policy and Using Social Media: Financial Advisor Tutorial PowerPoint. • Register Facebook, Twitter, and LinkedIn accounts with Smarsh for supervision and record retention. • Social media content must meet applicable standards for communications with the public as set forth in the Cadaret, Grant Compliance Manual and Social Media Policy. • Online discussion (chat) tools are prohibited.

10. What is Smarsh? • Smarsh is a Web-based product that allows Cadaret, Grant to supervise social media activity, as well as capture and archive both interactive and static content as required by FINRA and SEC rules. • Advisors must subscribe to Smarsh and register all business use social media applications with Smarsh. • Social media content will be captured and reviewed by Cadaret, Grant Compliance, much like business e-mail.

11. How Do I Register with Smarsh? • Submit an e-mail to the Cadaret, Grant Compliance Department at advertising@cadaretgrant.com to initiate registration. • Indicate the social media platforms utilized. • An activation e-mail will be sent to the user directly from Smarsh. • Follow instructions contained in the Smarsh activation e-mail to complete registration.

12. Standard Disclosure Requirements for all Social Media Communications • Include branch address, telephone number, approved business e-mail address, and approved Web site address. • Prominently disclose “Securities offered through Cadaret, Grant & Co., Inc., Member FINRA/SIPC. (Business Name) and Cadaret, Grant & Co., Inc. are separate entities.” • When referencing FINRA and SIPC membership, hyperlinks to www.FINRA.org and www.SIPC.org must be included. • Advisors must be registered in the respective state, prior to any direct communication with prospective clients located in states in which the advisor is not registered.

13. Standard Disclosure Requirements for all Social Media Communications (cont.) • When referring to services provided by an approved outside SEC registered RIA, include “Securities offered through Cadaret, Grant & Co., Inc., member FINRA/SIPC. Advisory services offered through [RIA Name], an SEC Registered Investment Advisor. [RIA Name] and Cadaret, Grant & Co., Inc. are separate entities”. • When referring to services provided by an approved outside state registered RIA, include “Securities offered through Cadaret, Grant & Co., Inc., member FINRA/SIPC. Advisory services offered through [RIA Name], a(n) [state] Registered Investment Advisor. [RIA Name] and Cadaret, Grant & Co., Inc. are separate entities”.

14. Standard Disclosure Requirements for all Social Media Communications (cont.) • When referring to approved outside business activities, identify the entity or person providing the service and disclose that they are not affiliated with Cadaret, Grant.

15. Social Media Communication Standards • Generally, advisors cannot control who the audience is so it is important to: • Assume the audience has little or no knowledge of the topic being presented. • Provide clear and concise information. • Avoid industry jargon or terminology unfamiliar to the public. • Avoid what FINRA calls “exaggerated and unwarranted” language such as “the most successful advisor in New York.”

16. Social Media Communication Standards (cont.) • Always provide a basis for the reader to evaluate the facts being presented in regard to any investment, security, or service. • Always present information that is fair and balanced regarding risks and benefits. • When expressing a personal opinion, include the following disclaimer: “This material is provided for general information only and is not intended to provide specific advice or recommendations. To determine what may be appropriate for you, consult with your financial advisor.”

17. Social Media Communication Standards • When comparing investments or services, disclose all the material differences including (but not limited to): • Investment objectives. • Market fluctuation. • Tax advantaged features. • Liquidity. • Fees and expenses.

18. Online Chat and Instant Messaging • FINRA/SEC rules require firms to supervise and retain instant messaging in the same manner as written correspondence, thus online discussion tools or “chat” functions within approved social media applications may not be used. • Using direct messaging and e-mail tools available within LinkedIn and Twitter is permitted. However, use of these tools within Facebook is prohibited • Advisors must follow the electronic communications (e-mail) policy found in the Sales Practices section in the Compliance Manual. (Content will determine what additional specific disclosures, disclaimer, or information will be required.)

19. Third-Party Comments and Posts • FINRA Regulatory Notices 10-06 and 11-39 address the application of NASD Rule 2210 to third-party posts on a social media application established by advisors. • If an advisor “adopts” or becomes “entangled” with a post, FINRA will treat third-party posts as the advisor’s communication and recordkeeping requirements apply.

20. Third-Party Comments and Posts (cont.) • To avoid “adoption,” advisors must not explicitly or implicitly endorse or approve the content of third-party posts and should block/disable the ability of a third-party to post comments or content. • To avoid “entanglement,” advisors cannot participate in the preparation of third-party posts.

21. Third-Party Comments and Posts (cont.) • Advisors including a testimonial relating to brokerage services must disclose: • That the testimonial may not be representative of the experience of all clients. • That it is not indicative of future performance. • If it is a paid testimonial (if applicable). • RIAs and Investment Adviser Representatives are prohibited from using any form of testimonial that relates to advisory or financial planning services.

22. Links to Third-Party Sites • Advisors may not establish a link to any third-party site that the advisor knows or has reason to know contains false or misleading content. • Advisors may not establish a link to any third-party site that involves products or services that are not approved by Cadaret, Grant. • Advisors are responsible for monitoring and knowing where their social media applications link to.

23. Recommendations Are Prohibited • Social media applications make information widely available to the public, and the advisor is not able to control or know the audience. • It is not possible to determine suitability for a broad, unknown audience, therefore, making specific recommendations regarding a security is not permitted. Omitting the name of a security does not make it any less a recommendation. • The regulatory requirement to determine suitability cannot be satisfied by the use of a disclaimer that no recommendation is intended.

24. Material Subject to FINRA Filing • Material that includes specific or generic discussion of the following must be filed with FINRA for approval: • Mutual funds (including ETFs). • Variable products. • Alternative investments (non-Traded REITs). • Unit Investment Trusts. • Municipal securities (including 529 plan). • All such material must be submitted to the Compliance Department (advertising@cadaretgrant.com ) prior to use.

25. Summary • Cadaret, Grant supports the use of Facebook, Twitter, and LinkedIn. • Social media applications used for business must be registered with Smarsh. • Refer to Cadaret, Grant’s Social Media Policy and FINRA Regulatory Notice 10-06 and 11-39.