Successful Social Media for Mortgage Lenders: Engage With Your Audience While Maintaining Compliance Obligations

Successful social media for mortgage lenders: Engage

with your audience while maintaining compliance

obligations

What is Social Media?

• Interactive online communication, in which users can

generate and share content through text, images, audio,

and video.

• Different channels/formats:• Microblogging sites: Facebook, Twitter, Google Plus,

Instagram

• Customer review websites and bulletin boards: Yelp, Google

Local, Citysearch

• Photo and video sites: YouTube, Flickr

• Forums

• Blogs

• Professional networking sites: LinkedIn

• Virtual worlds: Second Life

• Social games; Farmville

Social Media is

Ubiquitous

• As of January 2014, 74% of online adults use social

networking sites*

• Fully 40% of cell phone owners use a social

networking site on their phone, and 28% do so on a

typical day.*

• 33% of Facebook posts are done on mobile devices

according to HubSpot

• Social media has a 100% higher lead to close ratio

than outbound marketing

*Pew Internet Project’s research related to social networking

New Guidance for

Mortgage Professionals

According to the Federal Financial Institutions Examination Council:

“A financial institution should have a risk management program that allows it to

identify, measure, monitor, and control the risks related to social media.”

Social media: consumer compliance risk management guidance

Federal Financial Institutions Examination Council (FFIEC)

January 2014

• CFBP is clear in its guidance. Now lenders must comply.

You should be able to address questions or complaints in a timely and appropriate manner.

Reputation Risk

Even if you don’t maintain a corporate social media presence, you

still must be vigilant:

• Spoofing, phishing, “fraudsters masquerading as the institution”

• Employee’s communications via social media may be viewed by the

public as reflecting the financial institution’s official policies

• Privacy: members posting personal, sensitive, or confidential

information.

Critical Considerations

Oversight and Governance

• How to track and manage

• How to train

• When to say “NO”/Fight sales’ pushback

• Establish a code of conduct

• Train and re-train all employees, especially sales, servicing, marketing

• Have employees self-register their online presences through internal

company records

Step 1 – Create a Policy

• Define your social media objectives

• Set policies and procedures regarding the use and monitoring of social media

• Establish an employee training program that incorporates company policies and

procedures for official and unofficial use of social media

• Establish content guidelines

• Define a list of impermissible activities for employees

• Create a written plan that provides controls and ongoing assessment of risk in social

media activities

Best Practices: Policy

Creation

• Who’s doing the talking?

• Be listening

• Determine the rules

• Prepare for the worst

• Hold people accountable

• Make it a living document

Listening Channels

SET UP YOUR LISTENING CHANNEL

• GOOGLE ALERTS

• NEWSLE

• TWILERT

• LINKEDIN

• MENTION

• TWITTER

Step 2 – Monitoring &

Governance • Design a social media risk management program with participation from various

aspects of the business unit, including legal, sales, marketing, compliance, technology,

information security, and human resources.

• Create a governance structure with clear roles and responsibilities.

• Define oversight process for monitoring information posted to the internet.

• Set audit and compliance functions to ensure ongoing compliance with internal policies

and all applicable laws and regulations (CFPB, State Regs.).

• Establish reporting methodology for information to senior management on social media

risk issues

Considerations for

evaluating solutionsPre-Review vs. Post-Review

Multiple Content Types

Hosted vs. On-Premise

Admissibility of monitored data

Website monitoring

Replication of data

Contextual review (don’t flatten!)

Automated policy review

Dan Carroll /[email protected]

www.smarsh.com

facebook.com/SmarshInc

@SmarshInc

Linkedin.com/companies/smarsh

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