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FFIEC: Social Media Compliance Risk Management Guidance. Presenters: Michael J. Wallace, Esq. President CLIX MG Inc. Thomas Hardy Chief Technology Officer, CLIX MG Inc. Michael Whitbeck President RMUPI. Social Media Statistics. 93% of marketers use social media for business

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Presentation Transcript
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FFIEC: Social Media Compliance Risk

Management Guidance

Presenters:

Michael J. Wallace, Esq.

President CLIX MG Inc.

Thomas Hardy

Chief Technology Officer, CLIX MG Inc.

Michael Whitbeck

President RMUPI

social media statistics
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
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
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
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
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

  • Competitivedisadvantage, missing increased profits
  • Alienation of Loan Officers and Employees
  • Consumer expectation of on-line presence
  • Increase of marketing expenses
practical tips for compliance with ffiec guidelines
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 scheduleto 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
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Demonstration

www.acuclix.com

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Key Feature of AcuClix

Implements your SMP and complies with FFIEC/CFPB:

  • Review of Social Media, simple
  • Pre-approval of posts
  • Identifies links and groups for compliance
  • Reports for Employees, Management & Regulators
  • Archive for MAP Reg N (24 Months)
  • Library of forms, approved content, policies/procedures

Uses technology to lower your compliance costs

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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 period

Full refund within 30 days

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www.acuclix.com

Questions?

Social Media Policy Template will be emailed to you.

Thank you very much

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