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Social Media Compliance with Financial Regulation by Jeff Picozzi

10/07/2014

Social media compliance has hampered financial institutions' efforts to build a presence on social media sites such as Twitter, Facebook and LinkedIn. Social media is hardly new (I mean you are reading a blog now - feel free to leave a comment). Yet when it comes to social media, financial services companies are still using AOL accounts, but with good reason. With a long list of regulatory concerns to consider, financial institutions have been incredibly hesitant to join the ranks of the world's most social companies. However, financial institutions got some unlikely help in their efforts to connect with customers from the Federal Financial Institutions Examination Council (FFIEC) and their recently issued guidance for financial institutions' use of social media.

The largest concerns of financial institutions come from regulations surrounding customer data. At most financial institutions, all communications are drafted and reviewed before release as a part of the compliance management process. In real-time interaction on social channels such as Twitter and Facebook, there is no time for the communication review process. In a BrandRepublic article from late last year, one of the world's leading banks admitted that its social strategy was years behind. Before joining Twitter, it attempted to draft over 50 responses for use in customer interactions. Upon receiving the first question, the company realized that it did not have a predefined response for that question, which prompted a 3-hour review process before responding to the question. This approach will likely return better results over the long term as more canned responses are crafted for faster turnaround, but there are other questions that must be addressed.

When financial institutions are dealing with customer data, they must be concerned about where customer communications reside. In the world of social media, those communications are housed on external servers run by companies such as Twitter, Facebook and LinkedIn. When the communications exist outside the control of the financial institution, there are likely to be many people within the institution who will balk. Balk they have, much to the chagrin of customers, who increasingly look towards social outlets for communicating with brands with which they interact.

The FFIEC has stated that financial institutions should have a risk management program that allows it to identify, measure, monitor and control the risks related to social media. All social communications should be archived and included within a financial firm's records management program. This will add to the IT storage requirements for most financial institutions. And then comes the compliance question of when is comment posted on a company's Facebook page considered a complaint that requires a more formal response, and can you retrieve all of a customer's communications in a reliable manner.

While guidance from agencies like the FFIEC, FHA, and other regulators have made it possible for financial firms to have a presence on social media sites, It is no wonder why many companies are playing the wait and see game when it comes to open social.

The best defense against unstructured data and records is to have a single policy that governs information in all its forms. For more information about building a compliant and business enabling information governance program read Iron Mountain's Practice Guide to Information Governance for Financial Services.
LINK: http://blogs.ironmountain.com/2014/industry/financial-services/social-...
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