Social Media Compliance  
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You may be interested in reading my White Paper and Magazine Article:Back
February 2013 

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On Wednesday, March 6, 2013, I will participate in a webinar panel discussion on FFIEC's new Social Media guidelines, hosted by American Banker and Bank Technology News. I will be joined by subject matter experts in Internet technology, privacy and data security law, and Internet banking.

Jonathan Foxx
President and Managing Director 

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Recently, Federal Financial Institutions Examination Council (FFIEC) issued a request for comments, entitled Social Media: Consumer Compliance Risk Management Guidance ("Notice").  FFIEC issued this notice on behalf of its six members, Office of the Comptroller of the Currency (OCC); the Board of Governors of the Federal Reserve System (FRB); the Federal Deposit Insurance Corporation (FDIC); the National Credit Union Administration (NCUA); and the Consumer Financial Protection Bureau (CFPB) (collectively, the "Agencies"); and the State Liaison Committee (SLC).

Succinctly put, whatever the federal agencies eventually adopt, the states will issue the final guidance as a supervisory guidance not only to the institutions that are, by extension, under its supervision but also through the State Liaison Committee, thereby encouraging state regulators to adopt the guidance.

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The guidance offered by FFIEC is intended to help financial institutions understand potential consumer compliance and legal risks, as well as related risks, such as reputation and operational risks associated with the use of social media, along with expectations for managing those risks. Although this guidance does not impose additional obligations on banks and nonbanks, as with any new process or product channel, financial institutions must manage potential risks associated with social media usage and access.

With this in mind, we recommend the following outline as the de minimis sections for an Social Media and Social Networking Policy and Procedures, conceived as a Employee Manual to be provided to and receipt thereof attested to by all affected employees.

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