Social media is drastically changing the way banks do business and how they engage with their customers. The degree to which banks utilize the capabilities of social media vary by institution, but one thing is standard across the industry: you must remain compliant with all federal, state, and local laws regulating banking commerce.
According to CBANC’s article, “Managing the Compliance Risks of Social Media,” compliance is a huge focus when it comes to social media. “It introduces a unique set of risks in that it both connects millions of people and yet anonymously exposes potentially sensitive personal information or communications.”
The Federal Financial Institutions Examination Council (FFIEC) issued a report in 2013 entitled “Social Media: Consumer Compliance Risk Management Guidance” to direct financial institutions in their development of a cohesive social media policy.
- Show staff the basics of each media platform you will be utilizing. Do not assume that all staff are familiar with each platform.
- Advise staff on how they can use your social media platforms. Train staff on proper online etiquette. Request that they maintain a professional or neutral online profile and never discuss customer transactions.
- Review site-specific terminology for each social media platform.
- Set goals and objectives and identify the:
- Target Audience – who are you trying to reach?
- Engagement desired – do you want more followers or customers to take a specific action?
- Cross-functional teams responsible – will you have marketing, legal, operations, or other teams in charge of social media engagement?
- Identify the roles and individuals responsible for social media – will you hire interns for social media engagement or is the head of marketing responsible for publishing posts?
- State which process and technology should be used for customer engagement – should staff use only company computers or do you allow staff to post from private mobile phones or tablets?
- List the types of content that can and cannot be published – you must be clear that private customer transactions are never to be discussed on social media and that staff must never use profanity or derogatory language.
- Develop a content approval process – it is necessary for all intended content to be reviewed for compliance with institution policy and legal regulations. The approval process should be clearly delineated so that it’s viewed as an aid, and not a roadblock, to publishing content.
- Set a regular training and refresher training schedule for all staff who engage customers on social media. Technology changes quickly and new platforms are constantly being launched. It is in an institution’s best interest to ensure that their staff is properly and thoroughly trained.
- Establish a process where social media use is monitored and the guidelines are enforced. A financial institution has a lot at stake and needs to ensure that their reputation and confidential information is safe and protected.
Source: Wall Street Journal
After a financial institution develops and publishes social media guidelines, it needs to inform staff. In addition to reviewing the policy bi-annually to ensure that the policy is up-to-date with current law, staff needs to receive training every time a policy changes. The most important part of every policy is to keep staff informed and provide staff with advice on how to use social media in a smart and responsible way.
Finding time for regularly-scheduled social media training can be difficult. Here are a few methods to consider, which will provide training and reduce training time:
- Brief video tutorials, or micro-learning, to keep staff informed of any policy changes
- Include a social media component in every training class provided to staff.
Above all, staff must be cognizant at all times that social media interactions with customers are considered to be a part of the customer’s personal information and needs to be disclosed if this information is used in any decision-making process.
The FFIEC recommends that participants from compliance, legal, technology, marketing, and human resources be involved in developing your social media risk management policy.
Everything a financial institution publishes on social media is considered a part of its official communications. The rules of traditional advertising apply when you use social media to attract customers. All the disclaimers you would be required to print in a traditional newspaper advertisement are also required when you post an offer on a social media platform.
Developing and managing the social media guidelines can be intimidating, yet it is a crucial aspect of remaining compliant with local, state, and federal regulations. Once you have a comprehensive set of guidelines and training in place, you can embark on the social media journey and engage your customers online with confidence.