On January 22, 2013, the Federal Financial Institutions Examination Council (FFIEC) released a proposed Social Media: Consumer Compliance Risk Management Guidance (see http://www.ffiec.gov/press/pr012213.htm for details) for banks, savings associations, non-banks, and credit unions. Upon approval, financial institutions who have adopted social media and those who have not will be expected to use the guidance to mitigate risks posed by social media activities.

1. Quick Overview of Social Media Regulations for Banks
Proposed Guidance Summary of Federal Financial Institution Economic Council
(FFIEC) Social Media Compliance Risk Management Program
Strategy & Governance A governance structure with clear roles and responsibilities whereby the board of
directors and/or senior management communicate how usage of social media
contributes to the strategic goals of the institution, while also deciding on internal
controls and how ongoing social media risks will be assessed.
Policies & Procedures Implement policies regarding the use and monitoring of social media, and compliance
with all applicable consumer protection laws. Social media policies should incorporate
procedures addressing risks from online postings, edits and replies.
Vendor Management Manage third-party social media vendors within defined parameters to ensure
compliance with all regulations, customer privacy, and security of their financial data.
Training Establish an employee training program that incorporates the institution’s policies and
procedures for official, work-related use of social media, and potentially for other uses
of social media, including defining impermissible activities.
Monitoring Establish an oversight process for monitoring information posted to social media sites
administered by the financial institution or a contracted third party.
Compliance Audit and compliance functions to ensure ongoing compliance with internal policies
and all applicable laws, regulations, and guidance.
Reporting Generate regular reports to the financial institution’s board of directors and/or senior
management, “enabling a periodic evaluation of the effectiveness of the social media
program and whether the program is achieving its stated objectives.”
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