Today, it is rare to find a bank or financial institution without a presence on social media. A few years ago, this wasn’t the case. Institutions were strongly concerned about protecting the privacy of customers, and social media seemed to pose a high risk with compliance standards. So in 2013, the Federal Financial Institutions Examination Council put together a document titled, “Social Media: Consumer Compliance Risk Management Guidance,” which explains in detail exactly how a bank can avoid disclosure of customer information and issues with compliance.
The entire social media guide is about 11 pages long, so instead of providing you with a long, boring summary, here are four common compliance rules our agency encounters:
Be clear with contests
Under the “Unfair, Deceptive, or Abusive Act or Practice” section of the FFIEC document, it’s stated that messages published on social media must not be deemed unfair or misleading to the customer. For example, if a bank is hosting a contest on its page, it must advertise using very strict language. Using statements such as “enter to win” is not allowed because it suggests that if the customer enters, they will win. Instead, posts should say “enter for a chance to win,” which implies the customer may or may not win. For this same reason, financial institutions are not allowed to host raffles due to the unpredictable odds of winning a raffle.
Keep disclosures one click away
Chapman and Cutler LLP produced a Social Media Guide for Financial Institutions, which included the Federal Trade Commission Act that discusses providing appropriate disclosure to customers on social. The Social Media Guide states that required disclosures must be placed as close as possible to the claim. In most cases on social, especially Twitter, it isn’t possible to provide a lengthy disclosure. Therefore, the solution is to provide a link that is one click away for the consumer, keeping the disclosure as close as possible to the claim. If a bank wants to post on their social page about new loan they are offering, there must be a link with the post directing customers to all of the information about the loan.
Cite FDIC or NCUA advertisements
Anytime a FDIC or NCUA product is advertised on social, the institution must declare their membership. Something financial institutions must watch is what qualifies as an “advertisement.” According to the FFIEC, “an advertisement is defined as a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.” If you browse your bank’s social page, you’ll most likely see this logo on the images, or the phrase “Member FDIC” at the end of a social post.
Pyramax Bank out of Milwaukee experienced this issue during their testing phases of Meerkat. Read the full interview here.
Keep track of all posts
Under the Community Reinvestment Act, the document states that a financial institution must keep a file of all complaints or comments made from the public that relate to the institution’s performance in helping the community meet its credit needs. Obviously on social media, this task can be difficult. Enter a program called Social Assurance. This product is made for the purpose of helping banks with compliance on social media. The program keeps track of all messages posted and comments made on a financial institution’s platform. In addition, the program offers a simple approval tool that can be used between copywriter and compliance officer. With one click, the compliance officer can review and accept (or reject) every post. This is a great function to make sure the compliance officer has eyes on everything posted to the institution’s social pages and can catch mistakes before they’re live on the Internet.
Keeping compliance rules in mind, social media is an excellent platform for financial institutions. It can be used in a creative way to connect with customers and push campaigns to a bigger audience. Check out some of these financial brands utilizing social in their marketing strategy.
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Hurrdat is a Lincoln, Neb. digital marketing agency specializing in social media and content marketing. The company was founded in 2010 and merged with B² Interactive of Omaha, Neb. in 2014 bringing even more digital marketing specialties to both firms’ clients. Together they provide a full range of social media, SEO, and website development services to both national brands and local clients. The companies employ more than 75 people in Nebraska and have won multiple awards for their business efforts, company culture, and clients’ campaigns.
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