Banks, mortgage lenders, credit unions and other financial institutions have started using a variety of social media platforms; however, their online activities are now on the radar of financial regulatory organizations.
The Federal Financial Institutions Examination Council (FFIEC) decided to engage with banks and credit unions to make them aware of new requirements and compliance for social media policies. The FFIEC also presented these institutions with multiple pages of extensive policy guidance based on current industry regulations. The resulting comprehensive guidelines seem anything but social. However, here are some things that banks, credit unions and other financial institutions must consider when making their social media policy template.
Elements of Social Media Plans
The FFIEC recommends that social media plans logically begin with documented strategies that clearly describe goals and objectives for adopting social media communications within a company's operations. The information for this type of strategy can either be standalone or incorporated into the company's marketing strategy. The objective for this is to ensure that social media communications mesh with other marketing activities to engage the company's audience with one consistent voice. The financial investment that it takes to generate and implement social media plans is not lost on the upper management of financial institutions. Banks, credit unions and mortgage lenders that use social media will be expected to show the type of return on investment gained from using social media.
Social Media Policy
The FFIEC guidelines for financial institutions describe the need for policies that define the rules of engagement for social media usage by employees. A social media policy template guides financial institutions to define roles and responsibilities regarding the monitoring and creation of social media content. There is also guidance within a comprehensive social media policy template that describes the frequency and criteria for reviewing social media posts as well as the appropriate channels to report non-compliant posts to management. Representatives from a firm's compliance, human resources, marketing and legal departments are usually called upon to draft and review a company's social media policy.
Exploring the Legalities of Social Media Policies for Financial Institutions
The FFIEC guidelines prompt businesses to remind employees that using social media as a communication vehicle does not mean that they are not responsible for adhering to other government regulations. For example, the FFIEC's template and guidance documentation is based upon federal regulations such as the Truth in Lending Act, Bank Secrecy Act and the Gramm-Leach-Bliley Act Privacy Rules and Data Security guidelines.
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