Consumer compliance risks in social media

A hot topic is social media, but it has its risks, especially potential consumer compliance risks.

Recently, the Federal Financial Institutions Examination Council (FFIEC), which includes NCUA, released new guidelines to help financial institutions, “understand and successfully manage the potential risks regarding the use of social media.” It is important for credit unions, including their boards of directors and senior management, to identify and manage risks in the use of social media, including compliance risks. Many social media activities are regulated by specific consumer protection and compliance laws, several of which are highlighted and explained in this article.

You might ask, what is social media? Although social media is commonly thought of in the context of “friending”, “tweeting”, or “pinning”, the FFIEC guidelines concluded that social media is any form of interactive on-line communication. For example, in addition to Facebook, Twitter, Pinterest, Instagram, blogging and member review forms, email and text messages can be included in the definition. Email and text messages, if they stand alone, do not fall technically under the FFIEC definition. However, they may be subject to consumer rules and regulations. We recommend that emails and text messages be included in a credit union’s definition of social media.


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