Banking Law Journal Guest Article: A Look at Proposed FFIEC Guidance: "Social Media: Consumer Compliance Risk Management Guidance"

03/27/2013

On January 23, 2013, the Federal Financial Institutions Examination Council (“FFIEC”) issued a notice for comment on its proposed guidance, Social Media: Consumer Compliance Risk Management Guidance (the “Guidance”).

The use of social media by banks, savings associations, and credit unions, as well as by nonbank entities supervised by the Consumer Financial Protection Bureau (“CFPB”) (collectively, “financial institutions”), may increase a financial institution’s risk profile. The Guidance does not impose additional obligations but is intended to better inform financial institutions of potential consumer compliance, legal, reputation, and operational risks, as well as the expectations for managing those risks.

In light of the Guidance, it is increasingly important that financial institutions build the issues discussed in the Guidance into their risk assessment process as well as their enterprise-wide compliance management program when using social media to communicate with customers.

Excerpted from the Banking Law Journal, March 27, 2013. To view full article, click on the PDF linked below.

PDF - A Look at Proposed FFIEC Guidance: "Social Media: Consumer Compliance Risk Management Guidance"

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