According to the FFIEC, companies must develop employee training programs which incorporate a company’s policies and procedures for work-related use of social media.
These training programs can be broken down into two categories: consumer-facing employees (Loan Officers) and internal administrators (Legal, Compliance, and Marketing Departments).
Compliance, Legal, and Marketing Department Training
Based on its own risk assessment processes, a financial institution should also consider whether and how to respond to communications disparaging the financial institution on social media sites. One approach to managing these risks would be to monitor question and complaint forums on social media sites to ensure that inquiries, complaints, or comments are reviewed and addressed in a timely manner. These duties may be divided amount the Legal, Compliance and Marketing Departments. Adequate training will provide these department employees with: referenceable materials, approved response formats, an overview of any online social media portals used by the company, and training for any content creation or monitoring software utilized by the departments.
Be sure to create standardized responses for all social media inquiries and reviews (both good and bad) and create a hierarchy of escalation for issues of more serious concern. Check out our article for Responding to Online Reviews for some inspiration!
Loan Officer Training
Employee communication via social media may be viewed by the public as reflective of your company’s official policies or may otherwise reflect poorly on your brand, depending on the form and content of the communications. To mitigate these risks, establish policies and regular training to address employee participation in social media business accounts. For example, if an employee is communicating with a customer regarding a loan product through an approved social media channel, policies should include steps to ensure the customer is receiving all of the required disclosures. Here are some conservative best practices:
- Though leads may come through individual LO business profiles or social media accounts, to ensure that the proper disclosures are sent, your company may outline the Loan Officers must re-direct consumers to your company application portal
- Ensure that all content posted by outward-facing employees is approved by your Marketing Department ahead of time and reflects a standard set of disclosures based on the content
- Provide a list of typical “Do’s and Don’ts” that Loan Officers can reference. For example, to evade the possibility of forgetting “APR” in a rate offering post, instruct Loan Officers to avoid using any numerical rate offerings and instead use statements like “Let me help find the right loan product for your needs”
Remember the purpose of these regulations: to protect the consumer from fraud and misunderstandings. When creating content or evaluating a post, ask yourself “could this be misleading”?
Beyond employee business accounts, some organizations have also instituted guidelines for employee’s personal social media accounts. Below are some examples that have been added to social media policies, but it is important to note some states prohibit an employer from requesting these items from an employee. Be sure to review your individual states laws, regulations, and guidelines before proceeding:
- to add a supervisor or administrator to the employee account’s list of contacts (example a “friend” or “connection”)
- to change the employee’s account privacy settings
- to access personal social media in the presence of the employer
- to waive the rights and protections of the law as a condition for applying or receiving an offer of employment