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Presenters:
Michael J. Wallace, Esq. President CLIX MG Inc.
Thomas HardyChief Technology Officer, CLIX MG Inc.
Michael WhitbeckPresident RMUPI
FFIEC: Social Media Compliance Risk Management Guidance
Social Media Statistics
93% of marketers use social media for business
Social Media is number 1 activity on the web
45-54 age bracket is fastest growing on FB & Google +
YouTube reaches more 18-34 than any cable network
189 Million FB users are mobile only
FFIEC 12/19/13 Interagency Teleconference Definition of Social Media
“A form of interactive online communication in which users can generate and share content through text, images, audio, and/or video” Examples: • Company website (and all loan officer pages)• Micro-blogging sites(Facebook, LinkedIn; Google +, and
Twitter)• Blog sites (Yelp)• Photo and video sites (e.g., Flickr and YouTube
Key Messages/Takeaways
Existing compliance laws/regulations continue to apply to activities conducted through social media as they apply to activities conducted through other channels (CFPB- CMS)
Existing risk areas continue to be relevant – Consider particular ways social media can implicate those risk areas
Financial institutions will be expected to use the guidance in their efforts to adequately address risks raised by activities conducted via social media
Some Regulations
MAP Regulation N (24 months marketing material)
TILA/Regulation Z (Advertising of rates, terms)
FTC Unfair or Deceptive Acts or Practices
HMDA, ECOA – Anti Discrimination (Unique issue are links and group association. These may create perception and or regulatory problems)
Risks of Social Media
Using Social Media
Regulatory: As stated above, all apply Increase expenses of compliance: Reg. N 24 month requirement Reputation & Brand dilution: Colors, fonts, tag lines, links and groups Plagiarism, defamation: Improper use of copy-written material Current CMS/review not optimized for Social Media.
Not using Social Media
Competitive disadvantage, missing increased profitsAlienation of Loan Officers and EmployeesConsumer expectation of on-line presenceIncrease of marketing expenses
Practical Tips for Compliance with FFIEC Guidelines
Companies must have a written Social Media Policy
Employee Acknowledgment: Proof that it was read and agreed to. Links/Groups: Not violate company anti-discrimination policies Disclosure of SM: Base line Clear and Concise: Indicate what is appropriate, provide guidance Grading: Not required, but suggested.
Companies must show regulators that it is implementing the SMP
Review of Use: Institute schedule to review the SM based upon SMP Prior approval of posts: Recommended Archive: MAP Reg. N (24 months) Feedback to Employees/Training: Encourage compliant use of SM Reporting: Management and regulators
Key Feature of AcuClix
Implements your SMP and complies with FFIEC/CFPB:
Review of Social Media, simplePre-approval of posts Identifies links and groups for compliance Reports for Employees, Management & RegulatorsArchive for MAP Reg N (24 Months)Library of forms, approved content, policies/procedures
Uses technology to lower your compliance costs
Affordable Monthly Pricing
$ 150.00 up to 10 Users
Additional Users$ 4.00 11-50 $ 3.00 51-99
Maximum price: $ 500.00
New Year Special; Register 2/3 – 2/28; Unlimited $ 150.00 first 30 days
No contract periodFull refund within 30 days
www.acuclix.com
Questions?
Social Media Policy Template will be emailed to you.
Thank you very much