CU Compliance Connection. FFIEC - Social Media. Social Media.
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FFIEC - Social Media
Credit unions use social media in a variety of ways, including marketing, providing incentives, facilitating applications for new accounts, inviting feedback from the members, and engaging with existing and potential members. Since this form of member interaction tends to be both informal and dynamic, and may occur in a less secure environment, it presents unique challenges to credit unions.
The FFIEC published the Guidance to address the applicability of federal consumer protection and compliance laws, regulations, and policies to the social media activities conducted by credit unions and other financial service providers.
The credit union is expected to take steps to ensure that advertising, account origination, lending activities, and document retention are performed in compliance with all applicable regulations and laws.
The FFIEC Guidance states that BSA controls should apply to all members, products and services - including members engaging in electronic banking (e-banking) through the use of social media, and e-banking products and services offered in the context of social media.
The credit union should be aware of and address employees' communications via social media; which may be viewed by the public as reflecting the credit union’s official policies and may reflect poorly on the credit union, depending on the form and content of the communications.
Social media provides vulnerabilities to account takeover and the distribution of malware.
Credit unions should protect systems and safeguard member information from malicious software.
Social media should be included in the incident response protocol.
Thank you for joining me for this review of the FFIEC Social Media Guidance
Shawn Wolbert, CIA, CUERME, CUCE
Director CU System Relations
101 S. Washington Square, Suite 900
Lansing, MI 48933-1703
(800) 262-6285 Ext. 486
(734) 658-5427 Mobile
Follow me on Twitter – Shawn Wolbert @ Go2CUGuru