Is your bank or credit union preserving social media content? What? No. What are you thinking? You may not be in compliance with the Community Reinvestment Act which can have a tremendously harsh impact on your need for social media compliance for banks or social media compliance for credit unions.
As a social media attorney for the banking industry, I’m here to teach how your bank and credit union can comply with the Community Reinvestment Act by preserving its social media content. So first of all, what am I talking about?
The Community Reinvestment Act is a law that is designed to make sure that financial institutions properly serve community credit needs. It does so by requiring that banks both monitor written communications that come to the bank about the banks performance in community credit needs, and it preserves all these communications for a three year period of time.
Now, this has been easy for financial institutions to comply with in the past because people might write a letter or might write an email to you about your bank’s performance. Then you collect them and put them in what’s called your public file. How does the Community Reinvestment Act apply when it comes to social media?
You’re getting hit with questions and complaints from your community from all different angles. Whether it’s a direct message, a comment, a reply to a tweet, a comment on your post, a review on your page. These written communications can come from so many different places. Your bank or credit union needs to have a plan in place on how to comply with the Community Reinvestment Act on social media. So that you preserve all these comments, and complaints, monitor them, respond to them timely, and put them into your public file.
What does your bank or credit union need to comply with this law? You’d need to preserve your social media content on an on-going basis because it’s so difficult to know when a question or complaint is coming in. It’s not a very compliant thing to do to screenshot every comment that comes in. Think about this. You’d have to hire someone that’s going to be sitting in front of the computer for hours and hours and hours a day, just preserving every comment or tweet or whatever.
Instead, you should be leveraging some sort of technology that will preserve your social media content for you. You then have all your social media content preserved in one place and then because you should be having someone your bank or credit union monitoring your social media presence, they could flag any of those posts that relate to the Community Reinvestment Act and that post itself can then be placed in your public file.
By preserving your social media content regularly, monitoring your social media comments for compliance, and putting them into a public file. Your bank or credit union can breathe easy knowing that you’re complying with the Community Reinvestment Act because if you don’t, there are serious legal penalties.
Your bank can get audited. It can get fined, it can even have its social media profiles shut down for noncompliance and nobody wants that. I hope this blog has helped you to understand how the Community Reinvestment Act applies to social media and what you need to do to comply with that specific law.
There are many laws that apply to banks and credit unions social media profiles. The FFIEC Social Media Guidance requires every bank or credit union that uses social media to have a social media risk management program that covers things like the Community Reinvestment Act and everything else. From the Fair Housing Act, Truth in Lending, employee social media risks, reputational risks, et cetera. If you don’t have one, you are at risk of noncompliance with social media compliance for banks or social media compliance for credit unions.
So, how can your bank or credit union learn about what laws apply to use social media use and how to manage these risks? You can download our free guide on how to mitigate social media legal risks at your bank or credit union. Just visit financialfridays.co. That’s financialfridays.co, not.com because we couldn’t afford that domain name. It was like $2,000, but if you visit financialfridays.co, you could download our free guide on how banks and credit unions can manage social media legal risks.
And should your bank or credit union need assistance in setting up its social media risk management program or with social media archiving for banks, feel free to reach out to us at any time.
