Social media content is no longer only about sharing pictures of a vacation, being entertained by the musings of kittens, or watching a tutorial on how to bake chocolate chip cookies. For many, social media has become an indispensable source of information on all aspects of life, including news, finance, and investments.
Finance-related content on social media can appear in many different forms – for example, advertisements for financial products (whether or not declared as #sponcon or an #ad), ‘personal’ anecdotes about the content creators’ (aka ‘influencers’) experience with a particular product, service or topic, or ‘knowledge sharing’ on budgeting, financial management, or investment .
Many see the information provided by social media influencers as easy to understand, easily accessible, and in many cases, free (or low-cost), compared to traditional financial advice. This has led to the growing popularity of social media as an avenue to obtain finance-related information over recent years.
This trend has given birth to a new term, ‘finfluencers’. The increasing popularity of ‘finfluencing’ and the rising number of finfluencers have not only piqued followers’ interest, but also that of regulators. This is primarily due to the potential risks associated with providing inappropriate financial information on social media platforms and the potential impact that such content could have on the financial wellbeing of the finfluencer’s followers. Some areas of concern surrounding finfluencer content include:
In the traditional financial services and financial advisory space, the above concerns have been addressed through laws and regulations, including consumer protection laws or corporate laws, which stipulate that financial advisory activities must be conducted by licensed parties, and under the supervision of financial regulators. However, many finfluencers are not licensed financial advisors, and some might not even be aware of these laws and requirements that apply to them. The risks they potentially pose to consumers and the financial market are areas of concern that have prompted some new regulatory measures.
From a consumer protection perspective, financial regulators in the Asia Pacific (AP) region have taken digital tools and platforms into account in regulations and guidelines. The Monetary Authority of Singapore (MAS) issued Guidelines on Provision of Digital Advisory Service in October 2018 to lay out requirements on issues, such as licensing, technology risk management and suitability of advice for digital advisors.[i] A similar approach has been taken by the Securities and Futures Commission of Hong Kong (SFC). The 2019 SFC Guideline on Online Distribution and Advisory Platforms also provided detailed requirements on governance, risk management and monitoring of financial advisory activities, especially complex product advisory, provided through digital platforms.[ii]
In order to mitigate risks listed above, financial regulators have been educating the general public to avoid scams by issuing warnings on suspicious activities. Some regulators in the AP region have also provided guidance on how finfluencers can avoid misleading consumers. A few regulators have even taken a stricter approach by banning certain advertisement activities to protect consumers. These different regulatory approaches will be explored in detail in the next instalment of this blog series.
The increased use of social networking and the growing impact of finfluencers on consumers has also been associated with market events that recently raised regulators' concerns about financial market stability. For example, the market turbulence caused by "pump and dump" activities organized through social media has prompted regulators to study the potential role of social media and social networking in market manipulation. In an effort to better understand the use of digital engagement practices, the U.S. Securities and Exchange Commission (SEC) published a consultation in August 2021 to seek public feedback on broker-dealer and investment adviser digital engagement practices and regulatory considerations.[iii] The SEC will decide on whether to take regulatory actions based on the results of the consultation.
The roles of social media and finfluencers have also been analysed in the context of crypto-assets and their price volatility. In the IMF Global Financial Stability Report October 2021, "meme tokens", which refer to crypto-assets that are created for speculative purposes and are heavily influenced by social media, was mentioned as a recent example of how crypto-assets could potentially threaten financial stability.[iv] As regulators and policymakers continue to study the systemic impact of crypto assets, social media and finfluencers will be examined more closely. We will continue to track regulatory developments around this topic.
In the next blog, we will take a closer look at the consumer protection implications of social media and financial influencers. We will discuss the current trends among AP regulators in dealing with two types of finance-related social media content: social media advertisements of financial products, and social media content that contains financial or investment advice.
[iii] U.S. Securities and Exchange Commission, Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice, 27 August 2021
Akihiro (known as "Aki") is currently the C&I leader and Regulatory & Legal Support offering portfolio leader for AP RA and also takes up various leadership role in China RA as Deputy National Managing Partner. With 20+ years of professional experience, including more than 15 years in China, Aki has extensive international and local advisory experience in various projects and effectively helps large enterprises overcome the challenges to satisfy their business needs across Asia-Pacific Region. He has considerable experience and expertise in Strategic & Reputation Risk, Regulatory Risk and Operational Risk, including Banking & Capital Markets sector and Consumer Business industry.
Tony Wood is Deloitte China Risk Advisory Regulatory Support lead partner. He has rich experience in banking, financial services and consulting for about 20 years. He has worked for multiple SOEs, POEs and MNCs on their risk management and regulatory strategies in China and internationally and has worked directly with regulators across Asia Pacific on a broad range of policy, supervision and enforcement topics.