Presenters: Michael J. Wallace, Esq. President CLIX MG Inc. Thomas Hardy Chief Technology Officer, CLIX MG Inc. Michael Whitbeck President RMUPI FFIEC: Social Media Compliance Risk Management Guidance

Social Media Statistics 93% of marketers use social media for business Social Media is number 1 activity on the web age bracket is fastest growing on FB & Google + YouTube reaches more than any cable network 189 Million FB users are mobile only

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

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

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)

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 Competitive disadvantage, missing increased profits Alienation of Loan Officers and Employees Consumer expectation of on-line presence Increase of marketing expenses

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 schedule to 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

Demonstration

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

Affordable Monthly Pricing $ up to 10 Users Additional Users $ $ Maximum price: $ New Year Special; Register 2/3 – 2/28; Unlimited $ first 30 days No contract period Full refund within 30 days

Questions? Social Media Policy Template will be ed to you. Thank you very much