Social Media Compliance

Let’s make one thing abundantly clear: social media may be used to market your banking products and grow your online audience, but you must take steps to ensure that all social media activity complies with FFEIC social media guidance.

 

Your financial institution can’t afford to sit on the sidelines and not take advantage of social media simply because it is regulated by the FFIEC. Instead, you need to identify the specific risks that you are facing based on your unique social media activities and develop a plan on how to manage them. Since every bank and credit union uses social media differently, it’s important to understand how banking regulations apply to your bank or credit union’s social media use so that you can protect yourself from social media legal risk.

 

The best way to protect your financial institution is with a social media risk management program that complies with FFIEC social media guidance. A risk management program is not only a good idea – as it will help you avoid lawsuits, audits, and fines – but it’s also required under the law.

 

You see, the Federal Financial Examinations Institute Council (FFIEC) requires every bank or credit union with a social media presence to have a risk management and compliance program that identifies, measures, and controls the risks related to social media. Regardless of whether your bank is big or small, advertises financial products or just engages with your community, the FFIEC social media guidance requires you to have risk must be accounted for in your financial institution’s social media risk management program:

 

1. Corporate Governance: You first need to have clear roles and responsibilities for managing social media risks. You should have a formal risk management program that establishes controls and ongoing assessment of risk arising from social media activities.

 

2. Social Media Policies & Procedures: You also need to have policies and procedures for how you will use social media in a manner that complies with consumer protection laws and regulations. This may include marketing compliance checklists, a complaint policy, and proper terms and condition for social media sweepstakes compliance.

 

3. Employee Training Programs: Employees must receive training on your social media policies and procedures, so they understand how to use social media safely. At a minimum, you should have annual training programs for your marketing department as well as a company-wide employee training program.

 

4. Third Party Risk Management: If any third parties are involved in your social media activities, such as advertising agencies or technology vendors, you must have a risk management process for selecting and managing these relationships to ensure they follow financial and data privacy rules.

 

5. Oversight & Preservation: Every bank or credit unions needs to regularly monitor their social media profiles, respond to all comments in a timely manner, and archive social media content on a regular basis. Banks also need to place certain social media communications about the bank’s performance into its public file for compliance with the Community Reinvestment Act.

 

6. Compliance Audits: You must conduct periodic audits of your social media content and activities to ensure ongoing compliance with internal policies and all applicable laws and regulations.

 

7. Senior Management Reporting: Senior management must receive reports on a regular basis on the performance of your social media activities and how risks are being managed.

 

Since every bank and credit union is different, you’ll need to decide for yourself how you will build these components into your risk management program. This can seem daunting because the FFIEC social media guidance puts the burden on you to identify your financial institution’s specific areas of risk and what you will do about them.

 

So, how do you comply with FFIEC Social Media Guidance?

 

You can protect your financial institution from social media legal risk by developing a social media right management program that complies with FFIEC social media guidance. Since every financial institution is different, and uses social media in different ways, the first step is to conduct a social media risk assessment. 

Step 1. Conduct a Social Media Risk Assessment

Think of your assessment as an audit of your company and employees’ social media activities where we review and analyze your social media content, policies, procedures, and guidelines to assess your level of risk and compliance with financial laws and FFIEC social media regulations.

 

Step 2. Develop a Plan to Get Back into Compliance

Once we’ve identified your current level of risk, our next step is to develop a plan to get your bank or credit union back into compliance. Your plan will identify which policies, procedures, checklists, audits, reports, and training will be needed to protect your bank or credit union social media from legal risks.

 

Step 3. Build Your Social Media Risk Management Program

Your final step is to put our plan into action and start creating the appropriate policies, procedures, checklists, and training programs that will allow your financial institution to make the most of its social media strategy without fear of being exposed to lawsuits, fines, and regulatory scrutiny.

 

Let us Help you Move from Confused to Complaint

 

The Social Media Law Firm can conduct your social media risk assessment to determine your compliance with regulations that govern the banking industry on social media and FFIEC social media requirements. With our assessment in hand, you’ll have the tools you need to execute your social media strategies while eliminating social media legal risks.

 

By going through this step-by-step process with The Social Media Law Firm, you’ll be able to market your bank on social media with the confidence that you’re protected from social media risks. As experienced social media attorneys, we understand the complexities and frustrations you’re facing, and know how to get your financial institution back into compliance. In fact, we founded our law firm four years ago with a primary focus of social media compliance for banks and social media compliance for credit unions.

Having conducted many risks assessment for banks and credit unions across the United States, we can will know exactly what you need to get into compliance and what it will cost so that you can enjoy the peace of mind that everything is being handled correctly. Best of all, we work hand-in-hand with your compliance and marketing departments to make sure you can accomplish your marketing goals in a safe and compliant manner.

 

So, what are you waiting for? Contact us today to get your financial institution into compliance.