Social Media

1
Social Media Addressing Risk with Technology

• Scott Ferguson
• Lending Team Specialist
• sferguson_at_Smarsh.com
• 503 238 4995

2

• What are the main risks that you see in the use
  of social media?

• Reputational

• Regulatory

• Operational

• Legal

3

• Why is it so hard to identify and address these
  risks?

• Size

• Scattered

• Diversity

• Velocity

• Regs and best practices are still catching up.

• Dynamic

4

• How have financial institutions addressed these
  risks to date?

• No-Use Policies

• Pre-Review

• Monitoring and Retaining Content by Hand

5

• What is next? How can technology help today and
  beyond?

• Automate the rapid organization of this data.

6

• Now that this data is organized How am I
  expected to use it?

• Proactively through monitoring.

• Reactively through retention.

7

• A financial institution should have a risk
  management program in place that allows it to
  identify, measure, monitor and control the risks
  related to social media.
• -FFIECs Social Media Consumer Compliance Risk
  Management Guidance, December 2013

8

• The FFIECs Social Media Consumer Compliance
  Risk Management Guidance

• Social media may be used to market products and
  originate new accounts. When used to do either, a
  financial institution is expected to take steps
  to ensure that advertising, account origination,
  and document retention are performed in
  compliance with applicable consumer protection
  and compliance laws and regulations.

• TISA, TILA Reg Z, Fair Lending Laws, RESPA,
  FDCPA, UDAAP and CRA

9

• Scott Ferguson
• Lending Specialist
• sferguson_at_Smarsh.com
• Office 503 238 4995
• Mobile [phone]