FFIEC Provides Social Media Guidance
Earlier this month, the Federal Financial Institutions Examination Council (FFIEC) released its “Social Media: Consumer Compliance Risk Management Guidance." This 19-page document outlines the applicability of existing requirements and supervisory expectations—it was not published to impose any new requirements.
According to the document, the guidance is meant to help financial institutions identify potential risk areas to appropriately address, as well as to ensure institutions are aware of their responsibilities to oversee and control these risks within their overall risk management program.
FFIEC’s guidance clarifies how to follow regulations when promoting specific products in social media updates or ads (i.e. placement of disclosure information). FFIEC’s guidance highlights over a dozen individual regulations, such as the Truth in Savings Act (Regulation DD), Equal Credit Opportunity Act (Regulation B) and Truth in Lending Act (Regulation Z). Individual regulations are outlined beginning on Page 8 of the “Social Media: Consumer Compliance Risk Management Guide.”
Most credit union marketing and/or compliance professionals will already know how to comply with these regulations when marketing to consumers; the important part is to remember to extend these practices to social platforms.
For questions about existing regulations, please contact the Missouri Credit Union Association’s (MCUA) compliance department via email or at 800.446.3620.
The guidance reminds financial institutions to oversee any third-party relationships that provide social media or technology services. For example, if your credit union is working with a creative agency for content or posting, consider establishing a process that allows your team more input and control over what is posted to your credit union’s social networks.
In addition, the FFIEC encourages financial institutions implement a risk management program that includes:
- A governance structure that clearly outlines social media roles and responsibilities and who directs social media strategic goals, establishes controls and assesses risk
- Policies/procedures that ensure compliance with all applicable consumer protection laws/regulations
- Employee training program regarding policies for official, work-related use of social media
- Monitoring information posted to social media platforms
- Regular audit of ensure ongoing compliance with internal policies and laws
- Periodic evaluation of social media effectiveness to senior management or board of directors
Your credit union should establish a social media policy and ensure that staffers understand the policy. CUNA Mutual Group recently released a document to help with this process.
Need further social media assistance? Please contact Nora Holloway, MCUA PR and Online Community director, via email or at 314.542.1349.