Employee Use of Social Media Sites

Financial institutions should be aware that employees' communications via social media may be viewed by the public as reflecting the financial institution's official policies or may otherwise reflect poorly on the financial institution, depending on the form and content of the communications. Employee communications can also subject the financial institution to compliance risk, operational risk, as well as reputation risk. Therefore, as appropriate, financial institutions should take steps to address these risks, such as establishing policies and training to address employee participation in social media representing the financial institution. 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. This Guidance does not address any employment law principles that may be relevant to employee use of social media. In addition, the Guidance is not intended to impose any specific requirements for policies or procedures regarding employee personal use of social media. Each financial institution should evaluate the risks for itself and determine appropriate policies to adopt in light of those risks.

Source: FFIEC

The Highlights:

  • Lenders should be aware that individual employee social media may reflect poorly on the institution as reflective of company policy. 
  • Each lender should take steps to address these risks, such as establishing policies and training employees on appropriate social media practices.
  • Ideally, lenders should have sales staff operate out of a company controlled page to: comply with platform terms of service, ensure profiles reflect licensure appropriately, and create a degree of separation between individual loan officer beliefs and the company culture.