I’ll be honest, I’m not a big social media guy. I don’t use Facebook, Snapchat, Instagram, etc. Twitter is the only site I use, and it’s quite sparingly. But, I’m apparently not the norm. According to Google, 78% of Americans have social media profiles. The current number of users worldwide is 1.96 billion, with growth expected to reach 2.5 billion by 2018. All of this is to say that social media is extremely popular. It is also easily accessible and highly visible.
However, the use of social media for marketing strategies can present compliance concerns for credit unions. First and foremost, is the fact that there are no regulatory exceptions for social media advertising, as compared to more traditional methods such as newspaper, television, or radio ads. Even if regulators wanted to issue regulations for social media advertising, they would likely be out-of-date by the time they were finalized. Technology simply advances more quickly than the regulatory process.
However, to assist credit unions, and other financial institutions with compliance management of social media activities, the FFIEC issued its “Social Media: Consumer Compliance Risk Management Guidance” back in December of 2013. The guidance provides some excellent information related to examiner expectations, and areas of potential risk. I highly recommend that credit unions utilize this reference when creating, or updating their social media compliance programs.
Another resource I would highly recommend is PolicyWorks! We are more than happy to assist you and your credit union in developing or enhancing a program to monitor compliance risks related to social media. We can also review your credit union’s posts before they are made public, to ensure all compliance requirements are addressed. If there is any way that I can personally provide assistance, please feel free to contact me at any time.
In the meantime, I’ll leave you with my one and only social media joke. What do you call having your grandmother on speed-dial? Instagram.