1. Social Media – Addressing Risk with Technology
Scott Ferguson
Lending Team Specialist

2. What are the main risks that you see in the use of social media?
Reputational
Regulatory
-Defamation or Libel
Operational
Legal

3. Why is it so hard to identify and address these risks?
Size
Scattered
-Sheer amount of Data
-Can come up anywhere
-The context for one outlet is completely different than another. LinkedIn has a very different tone and context than Twitter or Instagram.
-Your institutions produce and receive data at amazing speeds.
Diversity
Velocity
Regs and best practices are still catching up.
Dynamic

4. How have financial institutions addressed these risks to date?
No-Use Policies
Pre-Review
-Sheer amount of Data
-Can come up anywhere
-The context for one outlet is completely different than another. LinkedIn has a very different tone and context than Twitter or Instagram.
-Your institutions produce and receive data at amazing speeds.
Monitoring and Retaining Content by Hand

5. What is next? How can technology help today and beyond?
Automate the rapid organization of this data.
-Once Organized , You can search and manipulate that data to help execute your written polices.

6. Now that this data is organized… How am I expected to use it?
Proactively through monitoring.
Reactively through retention.
-Alert you to potential risks (customer complaint, client-facing personel over-promising i.e. regulatory risk, profanity etc.)
-Stored social content can be searched to identify the root issue and uncover unseen risks, much like corporate being stored for HR or litigation purposes. -

7. “A financial institution should have a risk management program in place that allows it to identify, measure, monitor and control the risks related to social media.” -FFIEC’s Social Media: Consumer Compliance Risk Management Guidance, December 2013

8. The FFIEC’s Social Media: Consumer Compliance Risk Management Guidance
“Social media may be used to market products and originate new accounts. When used to do either, a financial institution is expected to take steps to ensure that advertising, account origination, and document retention are performed in compliance with applicable consumer protection and compliance laws and regulations.”
TISA, TILA Reg Z, Fair Lending Laws, RESPA, FDCPA, UDAAP and CRA

9. Scott Ferguson
Lending Specialist
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