Do you Know the Seven Key Components Under FFIEC’s Social Media Risk Management Program?

by Bill Dolan, CMB, AMP

The Federal Financial Institutions Examination Council (FFIEC) is comprised of the Office of the Comptroller of the Currency (OCC), the Federal Reserve System Board of Governors, the Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), and the Consumer Financial Protection Bureau (CFPB).

The council membership issued a social media guidance document to assist financial institutions that are supervised by the CFPB, including banks, credit unions and non-bank entities.

SCA is reprinting these guidelines to assist you in strengthening your internal Social Media Compliance Policy by creating an understanding of consumer protection and compliance laws, as well as policy and regulations applicable to social media activities. Here are the seven recommended components for inclusion in your social media risk management program:

1. Policies and Procedures

   • Having clearly defined social media compliance policies and violation response procedures in place.

2. Governance Structure

   • Identifying individuals who will be responsible for implementing and overseeing the policies and procedures.

3. Third-Party Relationships

   • Developing a sound process for selecting and managing social media third-party relationships.

4. Training

   • Implementing an employee training program that teaches loan officers what they can and cannot do on work-related social media.

5. Oversight and Monitoring

   • Maintaining continuous monitoring of employee work-related social media activity.

6. Audits and Reviews

   • Performing periodic audits and reviews to help ensure constant compliance.

7. Reporting

   • Providing a detailed reporting system that consistently disseminates information to upper-level management.

  If you are unsure how to develop a social media compliance policy that should be built off of the above guidelines, or are looking to have a social media assessment performed that addresses risk management in the areas of Reputational Damage, Compliance Violations, Regulatory Fines, 3rd Party Provider Relationships, Operational Policies or more, contact SCA at (617) 694-2617 or visit our website at:www.scapartnering.com to learn more about the consulting services we can provide.