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The FFIEC on Social Media

You hear the FFIEC has proposed Social Media Guidance? Don’t panic.  It’s actually a good thing.

Yep, the FFIEC finally weighed-in with proposed guidance for banks who have Social Media programs (Facebook, Twitter, Blog, etc.)  The proposal is comprehensive and provides all banks with some very solid,  useable guidelines to protect the bank from the inherent risks in Social Media.

A whack upside the head?

For many banks, Social Media has not been taken seriously.  Maybe that’s because SM has such an informal tone.  And, perhaps it is because most people, particularly bank employees, participate in SM away from the bank, usually at home.  But, SM has some unique (and serious) risks.  For example, a bad guy might hijack a bank employee’s SM account and use that unauthorized access to mislead bank customers.  And that’s just the tip of the iceberg.

So, banks should do a couple of things: first, they should take a good, hard look at just exactly how the bank is using SM, including their SM strategy; second, they should compare their SM use with the FFIEC’s guidance and come up with a SM Risk Assessment. (Actually, now that I think of it, this looks a lot like a Social Media SWOT.)

Next, the bank should take reasonable steps to be sure SM usage is adequately monitored and the risks are minimized.  This is not brain surgery. It is straight forward compliance 101.

Of course, just because it’s straight forward doesn’t mean it will be easy.

The problem is mostly a matter of doing what everybody agrees should be done.  This is often a matter of time, which nobody in the bank really has, or a matter of distraction — there’s so much other stuff going on, the SM Risk Assessment keeps getting put off.

An inexpensive solution?  Call us. We can get the SM Risk Assessment done quickly and inexpensively.  We’ll supply all you need:

  • Analysis of your current SM usage
  • Compare your current SM program with the FFIEC guidance
  • Perform a Risk Assessment, including a program of remediation
  • A system to monitor and report the bank’s SM program


Want to explore this?  Call me at 800-544-8269 or email me with SMGUIDE in the subject line.  Remember, there’s no charge to spitball ideas.