SOCIAL MEDIA DISCLOSURE

COMPANY

If the Firm currently (or in the future) maintains an internet web site and/or social networking page (LinkedIn, Facebook, etc.) or blog, each of which constitute marketing materials/advertising, the Firm shall also maintain reasonable procedures to ensure that prior to any subsequent, direct communication with a prospective client, the Firm and its representative(s) are first registered, excluded, or exempted from registration requirements in the state where the client resides. (See Compliance Calendar/Checklist as to State Notice filing and representative filing requirements). Moreover, additional substantive site disclosures should be included depending upon specific site content and links to third-party sites. Finally, the site should not elicit or permit testimonials, a statement by a current or former client as to the client’s satisfaction with/endorsement of the Firm’s services.