On January 6th, 2021 a group of people stormed the United States capital and infiltrated the House and the Senate. This was a tumultuous time for all Americans, and social media sites saw an unprecedented spike in activity. The mortgage industry was indeed part of that spike, with many loan officers, branch managers, and the like posting opinions on the topic.
While some social media sites like Facebook and Twitter have made pledges to ban accounts indefinitely for posts that have “inflammatory rhetoric encouraging insurrection” and others that go against their terms of service, lenders should be especially wary during these highly political times to ensure that employees don’t misrepresent the brand or cause undue harm to the company. How can lenders protect themselves from becoming front page news?
To minimize risk, each lender should begin by re-examining their social media policy. Do you have a social media policy? Is it free-standing, or baked into employment agreements? Lenders should clearly identify the risks related to social media (regulatory actions, brand damage, potential lawsuits, etc.) and then put restrictions in place to prevent foreseeable issues. Some lenders have outlawed specific social media sites for business advertising, while others have taken steps to include current event & other political trigger terms in their social media audits. A common policy stipulation for most lenders is outlining that loan officers can only use business social media accounts for mortgage advertising. Check out our article on Why Loan Officers Should Use Professional Pages on Social Media to learn more about this topic
With a policy framework in place, lenders can then begin to outline the workflow process. Lenders should evaluate how they are going to monitor social media, will there be a team from compliance or marketing who performs manual searches periodically? Or will social media compliance software be utilized for the task? In evaluating options, lenders should take into consideration the size of their sales force, the company’s level of social media presence online, and the time constraints of personnel, among other things.
You’ve got a policy updated & in place at your company, and you’ve got a process in place to find and monitor social media accounts, great work! Now, what happens when you find compliance issues online? The division of labor is critical to ensuring the success of any good policy. Lenders should consider the following: whose job is it to find certain issues, which department should be executing corrective action, and what needs to be done to solicit loan officer buy in. One way lenders can promote loan officer acceptance of and adherence to policy is by providing your sales force items with what they CAN do on social media vs. only telling them what they CAN’T do. For more on this topic, download our Social Media Compliance Cheat Sheet for LOs.
Finally, it’s important to note that social media compliance is not a onetime thing. It requires steady monitoring, with a consistent social media policy in place and a sound plan for when the worst case scenario comes to fruition (check out our article on Corporate Social Media Horror Stories to see how you can learn from other lenders vicariously). To ensure your company isn’t on the front page, you have to start ironing out these items today to make sure it’s not your brand in the paper tomorrow.
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