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Presenters: Michael J. Wallace, Esq. President CLIX MG Inc. Thomas Hardy

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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Presenters: Michael J. Wallace, Esq. President CLIX MG Inc. Thomas Hardy

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  1. 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

  2. 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

  3. 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

  4. 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

  5. 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)

  6. 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

  7. 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

  8. Demonstration www.acuclix.com

  9. 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

  10. 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

  11. www.acuclix.com Questions? Social Media Policy Template will be emailed to you. Thank you very much

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