FFIEC on Social Media: COPPA, Truth in Lending, Reputation Management


<span style="line-height: 1.5em;">The Federal Financial Institutions Examination Council (FFIEC) recently released consumer compliance risk management guidance on social media usage.  We've been taking a closer look at what this means for the institutions affected by the guidance. We look at ways in which organisations can protect themselves going forward. </span>

In <a href="http://www.hanzoarchives.com/banks-credit-unions-savings-institutions-compliance-social-media/">Part 1</a> of this series, we examined the broad impact of the new guidelines and how they highlight  five key risks around social media that corporations and organizations must address. We also considered “why” companies should address those risks.  Here we analyse some of the specific  examples and regulations ( such as COPPA ) mentioned in the FFIEC’s guidance on social media usage, something we'll be doing a lot more of as part of this series.

But as a compliance officer, general counsel, marketer or CEO of a financial institution, you'll be clear that it's not enough to understand what needs to be done or why it should be done. You need to know,  “HOW can I address those risks effectively?”

For example:

<strong>Truth in Lending Act/Regulation Z</strong>

How, in accordance with the Truth in Lending Act/Regulation Z, would your company demonstrate that the required information on a table or schedule that is located on a different page from the main advertisement is clear and conspicuous and the advertisement clearly refers to the page or location?


How, in order to comply with the Children’s Online Privacy Protection Act ( COPPA ), would a financial institution monitor whether it is “actually collecting any personal information of a person under 13, such as when a child under 13 manages to post such information on the financial institution's site?”

<strong>Reputation Management</strong>

How, in accordance with guidelines on managing your reputation online, would a financial institution monitor and address the fraudulent use of the financial institution’s brand on social media sites?

In each case, the 'how' requires your organisation to preserve an authentic copy of what was said and when as a basic prerequisite.  The FFIEC guidelines correctly identified that the explosion of web content and social media use has brought many benefits, but with it comes commensurate risks. Fortunately, the 'how' to manage those risks is now understood.

Hanzo’s true, native-format web collection and preservation services can help financial institutions reproduce an authentic experience and interaction that a customer would have seen on social media sites on a given date and time.  A flat, non-interactive PDF or MHT files can’t produce that, nor can an extract of data from the social media site itself.  Only a true, native file web archive can deliver

Hanzo can help demonstrate the controls and processes your company has in place and show compliance and the proper risk management procedures are in place.

Contact <a href="http://www.hanzoarchives.com/contact-us/">Hanzo</a> today for more information about how we help financial institutions meet their regulatory and compliance needs.

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