There is no question that Chatter is a game changer for Salesforce.  The Social enterprise and “social applications” are here to stay and need to be considered as critical aspects when designing applications on the Force.com platform.  That being said, organizations need to consider the impact and risks associated with implementing Chatter.

We recently encountered the challenge of implementing Chatter with a financial services client.  Financial services regulations and compliance requirements are broad and complex.  FINRA regulations require stringent rules in regards to how electronic communication by broker-dealers are captured and archived.  The primary requirement is related to communications with clients.  But most financial services capture and archive everything.  Social media, which I do not consider Chatter to be, has created significant risk for the industry. However, simply turning on Chatter is something that keeps compliance up at night as they consider the ramification and risk associated with this new form for communication.

So how should organizations implement Chatter and meet the FINRA electronic communication requirements?  Admittedly I am not a FINRA expert, and so I will always defer to FINRA rules and your respective compliance group.  Instead, I want to share the different options to capture and archive Chatter messages.  Here were several ways we considered approaching this problem:

Triggers on Chatter Messages – Implement a trigger on Chatter posts to send the message to either an email system (assuming it is being archived) or into a custom object. If a custom object is used, a report can be built on top of it.

Custom Visualforce Page and Apex – Build a custom VF page to query the Chatter feed. Provide an administrator the ability to run queries against the Chatter feed by different filters such as dates, post types and users.  The report can be automated and sent to an archiving platform or simply to email.

Customized Feed Integration – Take the Chatter content completely out of the SF environment and load it into an archiving platform by building a customized feed of Chatter posts.  You can also move the feed out of the Salesforce platform via an ETL tool like Informatica, however, this would require custom Apex code to capture the Chatter messages.

AppExchange Application – There are a couple of solutions available on the AppExchange specifically for capturing Chatter messages.  The products available take slightly different approaches and, depending on your archiving requirements, one or two may work.

These are certainly not all the possible solutions and each can be combined to fit your needs.  In addition to the solutions, there are a couple of items to consider:

Private Messages – Don’t forget about private messages!  These will be critical to capture and it does require some additional code and configuration.  The user that will be checking for the private messages will require their role enabled to manage the chatter messages to read the private messages.

Capturing Threaded Messages – One of the great aspects of Chatter is the back and forth comments that can be made on a post.  Depending on your specific compliance requirements, capturing the context of a comment may be important.  This will create some complexity on how you archive the Chatter messages.

Including Clients in Chatter – Enabling Chatter to outside the organization to clients and partners can be beneficial in creating a truly social enterprise, however, it also cranks up the risk and might not be within compliance requirements.

Chatter is certainly a powerful tool for an organization to increase their social quotient.  However, organizations need to consider the implications depending on their risk levels associated with the user community and topic context.

Post your Chatter compliance questions below and I’ll do my best to answer them.

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2 comments on “How to Implement Chatter and Meet FINRA Regulations

  1. Pete,

    Great post. It’s interesting to see that you’ve encountered the “Chatter Compliance Problem” with your Financial Services client. In our experiences, we’ve seen the same and we only expect this demand for Chatter archiving to grow, as folks continue to adopt the solution and recognize the need to be compliant.

    We’ve built an app, Archive for Chatter, that is a turn-key solution for Chatter archiving. The app is designed to get Chatter content (including private messages) out of Salesforce.com and into the email archiving solution that most regulated organizations already have in place.

    You can read more about Archive for Chatter via the following links:

    http://product.edynamicsllc.com/archive-for-chatter/
    http://appexchange.salesforce.com/listingDetail?listingId=a0N30000003KOgqEAG

    Thanks for the very informative post,

    Chris

  2. I appreciate the article as I work for a government entity that needs to maintain archives of all records created, including Chatter posts. Do you have any recommendations for archiving Chatter Messenger messages? I haven’t looked into that product yet, but assume archiving is not standard.