Social Media and Compliance for Banks and Credit Unions

hello everyone and thank you for joining
today’s session of a bank on social I’m your host Andrew Swinney and today I’m
joined with a special guest Joanna Belby She is a social media and compliance
expert a Forbes contributor and actually used to work with FINRA isn’t that
correct? that’s right thank you. yeah I’m so glad you could join us
so I wanted to go ahead and jump right in and just kind of hit you with some hard
questions, I guess. So, the first one it is it says in the FFEIC guidance the quote
is “a financial institution engaged in social media activities is expected to
be sensitive to and properly manage the reputational risks that arise from those
activities,” and so I’ve heard some people interpret that as a financial institution
engaged in social media meaning if I don’t engage I don’t have to worry about
anything so is it true that not being active on social totally clears you well
are there actually risks that are implied by not being active or created
by not being active I think the interpretation the standard
interpretation is that it doesn’t matter whether you co actively make a decision
to engage with social media as a bank or there’s just people talking about you on
social media about your bank you still have responsibilities to protect your
institution to protect your investors so a better approach is to whether or not
you decide to proactively use social media or not to have policies and
procedures around social media you know what are your processes are you looking
are you listening what are your clients saying about you when you how you gonna
change misperceptions correct things are incorrect you know so whether or not you
use it as a marketing tool or a way to engage your community you still are
responsible for the reputation of your bank and now you had this whole new
modality of people communicating so I don’t think you can stick your head in
the sand and say oh because we don’t have a social media program that means
we’re not on the hook for social media absolutely I mean the conversation is
going to take place whether you’re present or not so consumers can talk
about you which creates reputational risk potentially
you’re not being active they’re only contends that so would it be fair to say
that even if you’re not planning on using it as a marketing channel you
still have to have some awareness on there some policies at your institution
that define how you will be engaging or what you’ll be doing to monitor and
listen to those conversations is that fair absolutely absolutely I every bank
should have social media policies that lay out what’s allowed what’s not
allowed for their employees and if they’re not proactively using it or not
allowing or prohibiting their employees from using it what are the with what are
their communications plans around using social media what do they plan to do
when someone mentions their bank I just interviewed a CEO of a small community
bank last week and she started off on using social media just going on and
finding negative commentary on her bank and she proactively reached out to
people and some of these comments were two years old she proactively reached
out to them and and and found out what the situation was and she tried to
remedy it and that was very powerful and she her bank has gotten a lot of
attention because of that so is also yeah so you can use as a listening tool
you can quietly reach out to people you can reach out to people publicly if
they’re your customers you don’t want them to be unhappy you want to resolve
that issue right so it’s a it’s a tool that banks can use and whether or not
they use it they need policies in place describe what their thought processes
and are around around it nice I love that I love that it was two years old
and so she didn’t think that that’s too much time hasn’t passed by it’s a chance
to bring them back especially if there is a change in leadership and I think
that is a real sort of competitive edge that a lot of community institutions
have that they don’t recognize which is that the CEO of a mega Bank is never
going to reach out to you and try to find out what your experience was like
why things fell apart but a lower institution that’s a huge skill and what
was really interesting she found that those became her strongest advocates
because she reached out to them she resolved the issues she was very public
very helpful then they’re really brand advocates now for that Bank she turned
it up and around that’s incredible I love that example so sort of
like you know we’ve established this idea that you have to have some policies
in place whether you’re going to be actively marketing or not which means
that obviously if someone comes in to audit they’re going to be looking for
those policies so let’s pretend that you are going to audit a community bank or
credit union what kind of things are you looking for what kind of policies or
programs are you hoping that they have in place how do you be trying to not
catch them out but make sure that they’re doing everything appropriately
well there are existing rules and regulations around how banks may
communicate with the public and so social media is just another way of
communicating so social media policies can be either woven into existing
policies around communications with the public or they can be standalone so as a
regulator I would want to see those policies I would want to see what was
exact what was allowed what was prohibited at mine at the bank I will on
honesty training programs the best situations are where you have training
programs that define to help employees understand the policies as well as how
to use social media and then I would want to see that the social media
activities were being monitored and supervised in some way and I would want
to know the percentage of percentage of communications that were being monitored
and then I would want to make sure that the policies were actually be in that
being enacted the way they were written so you have something called a written
supervisory procedure where you lay out how you’re going to supervise your
employees and you have plan around that so regulators want to see that written
supervisory procedure but then they want you to evidence or prove that you’re
actually following your own procedures so one of the things I always am careful
to talk when I speak with banks that they need to remember as they put
together these policies they should be doable
they should be enforceable they shouldn’t be overly optimistic of what
they’re gonna supervise or monitor because the bet the regulator’s are
going to want to see that you’re adhering to your own supervisory
procedures so that’s the first thing they do so they might go to a
headquarters and everything will be fine but then they’ll go to a branch and
they’ll see wait not everything’s being adhere to at the branch level to follow
your own policy is what I would say that guy
brings to my mind the problem that we’re facing more and more which is that the
lines between professional and personal and blurry and everyone wants to help
out their business and the many times a business wants them to they’ll send a
email to everyone saying hey we’re really excited about this can you tweet
about it can you post about it to your friends and sometimes ITR to themselves
how how did those policies relate to managing employees or making sure that
you or at least there’s no dark areas where things can catch you off guard of
the kind of policy should be there and how actively do you have to be
monitoring your employees to make sure they’re adhering to those and that
you’re documenting to show that to me when it comes into audit that you’re
getting evidence that yes we are actively monitoring employees give me
any thoughts about that this is a very difficult area the if you’re using if
you allow your associated persons say your advisors financial advisers to use
social media for business it’s pretty simple they they give they get
permission from their bank to use these tools for business they agree to have
these their records all their communications archives and captured
make it discoverable and monitored and it’s pretty clear-cut they know that
they’re using LinkedIn or Twitter or Facebook for business banks typically
offer pre-approved content that they can share and they have thier sets of
guidelines on what they how they can use social media for business or in the
workplace because we know the regulator’s really don’t care about
personal communications they’re not interested in hey John let’s meet for
lunch at twelve o’clock they’re interested in hey buy Apple stock it’s
gonna do great I mean they’re interested in business communications so that’s
pretty clear clear-cut and a lot of banks have done that and there’s
training programs and there’s technology vendors you can use to help monitor all
that the part that becomes really difficult is we’re human beings and we
have a whole life and we have our own political views and we have opinions
that may not be popular and so it’s a very difficult situation where an
employee might be very visible you know I am I my
Twitter handle is at Belle V it’s really easy to figure out who I am all you have
to do is look on my Twitter account then you could go to LinkedIn you could go to
Facebook although my privacy settings are closed but you could go on google
you can think out Who I am and where I work and so if I said something that
upset people that people found inappropriate they could conceivably be
chat to my employer and depending on the employer and depending what was said
there could be real issues there so it’s a very difficult situation I think the
best approach is for people need to be sensible and realize that nothing ever
goes away and everybody can find everybody you can even find somebody’s
personal address we certainly know daxing where people show can show up at
your apartment right yeah which for me is not a big deal because I have a
doorman like him deal with it but you know if I have a house in the suburbs
that would be something really scary right they have someone’s house like
somebody didn’t like something I stay so I think having common sense and I think
firms really do have a responsibility to teach their employees have it be
sensible so if they’re going to have social media policies and their
employees are going to be using them for business I think it’s appropriate to
have the ex next door step and say here the types of things you need to think
about before you post everything is forever
you might you think about before you post you don’t want upset people because
it’s to reflect back on you as an individual as a professional and it may
reflect back on us as a bank I’m not so true there is this weird evolution
that’s happening and I think sort of people who grew up in the social media
image get that really well maybe too well on Cecily so but now we have to
always be considering our personal brand no matter no matter what your role is
you do have a brand of reputation and that lives in all spheres of life
because we are so connected you dance before that maybe you have these
different social groups and keep those kind of sides of yourself independent
for better or worse but now they are there and yeah it’s totally connected
and there’s this palace example Bank of America employee who goes home for a
personal account and talks poorly about customers in a really derogatory way
that viral and she had me father’s and that
that principal whole new area of how do you balance like your research are yeah
and also her rights as an employee it’s a hard spot right now and there’s no
expectation of privacy at the workplace right that’s the thing people need to
understand that they’re using work equipment if they’re using social media
for business it is more likely than not being captured archive may be
discoverable to your legal and compliance department and your HR
department to be really clear just like their emails have been monitored for
years nothing different here but it’s the it’s that personal public persona
now that we also need to think about and just to take that extra step but I want
this on the front page of The Wall Street Journal if I don’t that I
shouldn’t write it yeah right is it misspelled doesn’t make sense is
it wrong you know and so it’s that extra caution that I think is even more
important now you even find five years ago when we were first using social
media you could make a lot of mistakes and no one really cared or knew there
weren’t that many people on it but there’s so many people on social media
now it’s much more dangerous place to play I think I mean the whole world is
there basically you’re right I mean there’s two billion people on Facebook
alone so chances are you’re your neighbors are on there you’re committed
your mom I know my parents are for better or worse I blog both and then and
then depending on people’s settings sometimes I’ll make a post on a comment
on Facebook and suddenly I see a past employer on there as well I’m like wait
a minute you know I if there’s no privacy anymore so if you decide to wade
into social media you need to be prepared to completely lose all sense of
privacy and there’s a generally that’s a great thing yeah I mean I think how much
of a story like as a tip for anyone who’s watching if you have a hard time
encouraging your executive to be on social media the most compelling pitch
I’ve ever done has been walking into a room opening up Twitter and then
searching their name within quotes and showing that people are already talking
about that person talking about past interviews or sales pitches or whatever
and when they saw that hope people are talking about me that was such a
telling arguments they were like I need to be here yeah so I mean that it is
totally true that people are going to talk about you that’s true for you as an
individual and as a brand they also saw that I’ve worked for a
technology company that used that monitored and captured communications on
social media and we would go into meetings with the salespeople and the
client would say oh our employees are not on social media and I would just get
on my computer and I thought what’s the Wi-Fi code here and I’d come on and I
look up LinkedIn I asked I’m not there be a thousand employees I’m linked it
and the guy with the wait a minute our policies are that we can’t be on social
media I’m like well you know what you care something right so have a plan
assume that they’re gonna be on social media have a plan do excellent training
make the training relevant I’ll make it include cybersecurity issues as well
because that’s a big issue on social media that not everybody’s talking about
that we become more susceptible to hacking and malware and the things on
cybersecurity because we consider ourselves a tribe and we tend to be much
more trustful and you’re not naive almost when are on social media and that
is to our detriment yeah that’s an interesting point I mean
social engineering is something that is becoming more and more politican the
entry way for hacking it’s responsible for so many packs even within corporate
things yeah so I think that’s great advice definitely the people are turned
up on they’re connected to that and connected to an idea you said earlier
you were talking about how if an employee is using company machines you
know obviously there’s that expectation that’ll be archived somewhere but you
also have written about the environment where people bring their own devices and
you’re trying to manage that so do they need like suggestions on how you build
policies or manage the employees using their own devices within the branch or
what kind of concerns is that weighs well at the end of the day the
regulator’s seek to protect the investing public consumer the patient
right they they seek to bring that for firms to protect themselves and their
proprietary information their client information
and the industry as well and so therefore the regulator’s don’t care
about the source of the communication for them
content is determinate meaning it doesn’t matter if it comes from a
corporate provided device or bring your own device whether it’s in your office
or at Grandma’s house at Thanksgiving if you’re using social media or anything
really to Kentucky’s that’s what the regulator’s are interested in so the
many firms use technology that will allow them to capture an archive can’t
you know text email on personal on personal devices so what I’m beginning
to see is a opposition to that and that more and more people I know are begin to
carry two devices they’re going they’re kicking it old-school and they’re gonna
keep their one device for business and another device for personal and I think
that’s a great idea that way there’s so no mistakes to see
very easy surfer accounts you know like not only do you have two devices that
you have two accounts you have maybe your work persona in your home persona
does that keep you safe or again do the lines blur with that who could figure
that out I’m sure that happens I especially in the larger broker-dealers
where advisors are now being allowed to use social media for business and it’s
all very curated and there’s a pre-existing content and you know it all
sounds very you know official and interesting for banking or financial
advising I wouldn’t be surprised if they didn’t have their own private accounts
for social media and we’re not associated with it with the banking
institution and then but at the end of the day it’s really easy to forget where
you are right I mean I have up at one point I I had access to my corporate
Twitter handle and my own personal Twitter handle on the same phone I used
to tweet under the wrong one all the time I just it was in France um I would
say you know you’re on your you know you’re on your business account right
now Joanna right and they would tweet at me on the corporate account and I was
like I’m sort of land and what am I talking about you
don’t talking about regulatory requirements FINRA SEC my stuff is so
bland it was not offense over irritating to anyone on either side
right but he could have been and it in the show oh yeah and I’ve been doing
this a long time and I still made those mistakes so i really suggest separate
devices not mixing them up it’s so easy to make a mistake and so I when I
upgrade my iPhone I’m now gonna I’m gonna switch I’m gonna keep my existing
one just for business and I’ll use a new one for personal that says why you’ve
talked a lot about you know or we have about enough devices to making sure that
we record things appropriately and setting up systems in order to make our
lives easier and also more compliant without making you have to recommend
anyone specifically you can if you want but are there specific systems or tools
who think that every bank created should be looking to have like some sort of
archival system or some sort of listening system something like that well that’s that’s um as an easy answer
as I’m an employee of proof point so proof point offers technology that
allows for firms to be able to use social media for their associated
persons and capture and archive and monitor those communications and meet
the regulatory requirements but even if you don’t use proof point I hope you do
firms need to find a provider and there’s a number of providers that in
the space and we’ve been in the space for a number of years and so pick one
you know do an RFI figure out the one that’s the best one for you really do
due diligence when it comes to selecting a vendor make sure your vendor is very
secure when it comes to cyber security for regulators are very concerned about
third-party vendors now and how they can allow on Bethan things to happen to
firms so your third-party vendors that you hire have to be as rigorous as your
own policies and procedures they should have training they should be very
careful themselves so there are certainly technology vendors in place
that can help firms it compete comply with those regulatory requirement
yeah it will have a link to group point for other videos so they was messaging
me I didn’t find right there so I heard you speak once before and you
talk to talk about the the idea of adoption and entangled it can you
quickly just summarize what what the concern is there with the documenting
what that is what the concern is okay so adoption and entanglement is a
concept that I first read about through this curious exchange commission I’m not
sure that’s where it originated but that’s where I know it from so it means
that there’s there’s different areas of responsibility when it comes to
advertising so if I adopt something in other words if I if I take it in and I
approve it I recommend it I share it that I become responsible for that
content just as if I become entangled in content if I’ve had something to do with
the writing of it but the changing of the procurement of it I become entangled
in the content in either case I now have record-keeping requirements for third
party content it really goes back to this regular requirement that you need
to keep accurate books and records for all your communications to do with the
business so when you when you’ve adopted third party content or become entangled
in it it had some sort of place in creating it you now are responsible for
it and so in when firms started using social media at first they would
typically just use their own company’s content whatever content that was on
their website whatever content they created they would have their advisers
use that content and it was all pre-approved
through their compliance department everything is fine but there’s only so
much content that’s available in house and so firms would want to share
third-party content articles from the times I lost eternal or business
publications and so if I now in sharing that content that means I’ve adopted the
content and now I’m responsible for it so not only do I have to capture an
archive the the content that my firm is created I have to catch an archive the
firm that a third party is created and I also have to make sure it’s it’s
suitable is it saying things that I think are appropriate so
it adds to the responsibilities for the firm when you use third-party content
and that adoption and entanglement concept that originated from the SEC was
actually included in the early FINRA guidance around social media around the
requirements for capturing third-party content when it comes to a broker-dealer
and that can be as simple as a retailer or share that showing triggers that yeah
do you have to then go and do things like link audits so let’s say i retweet
something a year ago a blog post and people it’s common practice to update
blogs right and so do i do then go back and look at these links from a year ago
and see oh wait now this doesn’t really align with us now there’s something here
this whiskey that I don’t feel so great about or just documenting it at the time
of retweeting there’s not enough to cover us what do you think I think
probably both I think you should probably document that and also that I
can do a link on it just to say exactly exactly so I mean what are the
regulators want go back to that the regulator’s want to protect the
investing public so something that you might have posted you know last year
might be completely appropriate but then what happens those links kind of they
could break there could be some really controversial things happening in the
comments that you don’t want to be associated with the person did the blog
could update it and change it so I think the best possible world is that you have
a really clear understanding what you’re posting today and then have policies and
processes in place to be able to periodically check to make sure you
still want that content available and associated with your brand I’m wondering
about your thoughts on what you do about the inverse right so again it’s it’s
easy for your message to get shared the things you get published and it shared
retweeted what does a bank or create responsibility from monitoring how it’s
used from there do they have any or once someone retweets it is the content now
there’s and any misinterpretation sort of falls on the readers hand or their
hand I don’t know I’ve never really thought about that so content that I’ve
developed as a community bank they’ve been
exactly so like let’s say I’m a bank and I say hey we love our Sammy’s account
you should check it out a customer then retweets it and says I have a savings
account I love it love the 2.9% you know if you why now you know obviously that
would sort of some concern for a compliance team if I was to post that at
the institution but now in employees or customers done it so how does that well
as I change things I would avoid the whole situation in the first place by
not talking about product not talking about savings accounts or CDs or
products or services instead having content that’s evergreen it’s going to
be appropriate for everyone you know how to save for retirement how to make sure
you’re properly insured I mean you know all the the core things that we need to
concern ourselves when we do we take care of our own wealth in our future
things that are not gonna really change or are not promotional in any way and I
don’t think people really want promotional pitches on social media
anyway they don’t really want to read about CD rates and it’s free checking
accounts and all that stuff I mean so when you do all that now you have always
to cloak disclosures and you really open yourself up to a lot of risk it’s better
to stick neutral and be helpful again going back to the community banking
example really how do you help your community how do you share the spirit of
community do you promote your little league are you in the aisles of your
grocery store how are you growing businesses how
you’re helping your businesses use social media and build as a community
those are things that you’re never gonna get into trouble with with the regulator
yeah and as you were saying it is the most effective content strategy and it
actually builds relationships that will naturally organically turn into sales so
I love that another role I was wondering if I could explain is the one click away
rule so we’ve seen people have been kind of confused about that what exactly does
the rule mean and does it doesn’t cover everything where there’s no specific use
cases well I’m gonna read something I just want to make sure I’m clear about
this so it really was found in the commentary to regulatory
z truth-in-lending and regulation DD crew the truth and savings and the
concept is if when you’re talking about something specific that has a lot of
text that you can’t include in a tweet you have to be one click away from all
the real information and the risks this is the concept that’s also used in other
field as well and so firms that are in regulated industries that need to
disclose risks need to figure out a way that include the risk and the initial
update and then be one click away and easy click to find out more information
so the rule is that you have to make it known that there are additional pieces
of information there are the risks there and then the next click has to go to
that so in light of that would you recommend institutions as a best
practice and use landing pages and speed bumps to help make sure that they’re
always into compliance is that an effective way to respond to that rule or
to make sure that you’re safe you know it’s hard because people are mobile
devices as well I mean so yeah I don’t know I don’t know the answer to that I
just look again go back and what’s the safest thing for the employee the
investing public and what we’ve seen this disclosure is about larger and
longer and longer and longer as a point where nobody ISM anyway so that’s a real
problem for regulators they really straw that with that they know they’ve created
a nightmare and so I actually heard like waves of disclosure where there might be
an initial comment that’s very clear-cut and short that anyone could read on any
device and then you can click to another yet more descriptive in-depth
description but I can’t speak for the regulator’s I just know that the concept
is it has to be close by you need to be access it not dig through is that it
can’t be the equivalent of Mouse type or like really digging through it needs to
be easily acceptable and when you’re making that decision you need to be able
to see what the risks are immediately do you think we’re going to see changes to
that point that you know it has turned into this huge monster do you think
we’ll see changes where the rules change we’ll see something much more
I don’t know but they will see rules changes but I think that there’s gonna
be a lot of we’re having this conversation for the last year or so
around maybe longer around disclosure so how do you make them more accessible for
the investing public and I think that people are struggling with that I don’t
I think that there’ll be a solution at some point with technology I just don’t
know what the solution is yet interesting to watch for sure yeah go
back to go back to keep thinking always go back to protecting the investing
public investing the patient investing protecting the consumer how do you
protect them you need to disclose the risks so how do you do that
in a way that they understand it yeah so is having transparency so that the
forefront of whatever you’re doing we I read an interesting article that you
have done and you’re talking a little bit about concerns that maybe aren’t on
everyone’s radar and he made you mentioned you know how do you respond if
you know let’s say Trump will retweet you you know regardless of your
political standings some people will like it some people might not like it
what are you know what are some concerns that you think maybe aren’t on people’s
radars actually that belief right like the things that people aren’t
necessarily thinking talking about that should be well I think it’s very
important and it’s always been important but even more so today to have a good
crisis communications plan to know who needs to be at the table in the event
that your brand is mentioned or there’s a crisis of some way so and the crisis
could be different things it could be a brand crisis someone could be the
President of the United States could mention you on Twitter
or it could be a crisis that there’s a hurricane and your branches are closed
so there’s a lot there’s lots of opportunities for crisis and so it’s
important to have plans in place and to know who needs to be at the table legal
compliance HR senior management what is their phone number how do I escalate and
another thing that’s important is remember this is a 24-hour
seven-day-a-week life we live and so something terrible
might happen on a Saturday and so do you want the most junior person on your team
managing the crisis no of course not so but that person needs to know who to
call and then that person needs don’t knows who to call and so it’s even this
the old-fashioned telephone tree needs to be in place that everyone has a copy
of so that in the event of something happens you can get the right people at
the table to make the right decisions now the smart firms that I’ve seen the
more conservative ones they actually have tabletop exercises where they
create they go into a room for a couple days they create a crises and they
figure out how to solve the crises and it becomes abundantly clear who needs to
be at the table as they go through that and so once they have that you know it’s
almost an amulet against future crisis the better plan the more plans you have
in place the better it will be when something happens and something will
happen you know it will yeah absolutely I love that I think that’s actually kind
of interesting and fun to watch no sitting around ahead and working their
way through it and they’re coming bristles I guess that like I mean I
think that everyone should do that right because it really does test your plan
and make sure that should some of these things happen you know how you’re going
to respond and it gives you that practice of going through it are there
common crises you think that every bank shouldn’t renew against I can think
obviously like a disgruntled employee or really upset customer the obvious ones
but are there any other that you think should be on that short list of things
that you should be prepared against and sort of drill against I think it’s
important more so than ever before to have a crisis communications in place
and plan a plan in place you know who needs to be at the table when when bad
things happen because you know there are there will be crises and this more and
more so as used to mentioned a disgruntled employee a very unhappy
customer so they could really quickly ratchet up into a big crises the other
thing to think about are we’re seeing these weather disasters or closers and
there have been certain circumstances like back and Sandy and more recently
where you didn’t have access to their website but people were able to tweet
out information on Twitter or share on Facebook on where to get to certain
supplies and what certain things would be open in other words using social
media as a channel channel to communicate with your customers and
your prospects and your community in the event of a crisis so it’s another way to
be able to reach your community tell of that so I want to go to the flipside
thank you I think that’s really interesting which
is is there such thing as over preparing or over handling a crises you know
something that maybe would have been that big of a deal but because we’re
suffering or risking something triggers we pour onto it and that’s automatic
we’re preparing the way that there’s paralysis we can’t effectively market
because we have so much in place it becomes this huge Barneveld slow little
machine well I think you see a lot of the latter in place
firms are very afraid they’re very protective of their brand I mean you
could take a hundred years to build a brand and destroy it in a day so rightly
so firms are concerned about social media and rightly slow so they’re going
very slowly in many cases really putting together content that’s appropriate
they’re having it vetted people are reading it it’s not slapdash and it
really shouldn’t be because they really need to protect the reputation of the
bank because after all I mean this is where our wealth is is is where our
money is so we need to feel comfortable as consumers that they are sensible and
reasonable people so I don’t think you would ever over respond I don’t think
you’d ever over prepare for anything yeah that’s great I’m not gonna quote
here from your interview Ethan in law they were actually be
talking to later this month but he said for me I will I’m out there so he says
here banks face the roadblock replying inflated laws to new technologies and
that is something that we talked about already but the rate of change right now
for social media is extremely fast and where’s some new content new platforms
and your media types but then the rules are kind of staying the same so other I
mean we’ve talked about it a little bit but are there evergreen rules that you
think things should keep in mind obviously think about the consumer think
about their perspective whether other ones I think documenting
everything probably a safe bet but over there otherwise you want to pass along
it’s important to have social media policies in place and it’s important to
applaud them over time based on your own experience because after all things
change the network’s change what we’ve seen the industry changes you might
start social media program in a very lockdown position where not many people
are allowed to do much and then evolve it over time so having good robust
policies are always important and updating them on an annual basis it’s
also important to have key stakeholders at the table so it’s not just marketing
and communications and Investor Relations but data and IT and HR
marketing the heads of business the more stakeholders you can have the table to
about those plans to better because they’re going to understand all the
risks for the business you may or may not understand so create this policies
with key stakeholders update them frequently and it’s also important to
get out there and look on social media and see what’s going on attend events
look at webinars if you don’t want to leave the office keep yourself up to
date and update and vary your policies accordingly training is also very
important it’s required are the regulators and it’s important to let
people know what they’re allowed to do what they’re not allowed to do and the
consequences of not adhering to those policies and make sure you follow
through on those consequences whatever they might be and then again yeah I mean
don’t make promises you don’t keep so make it very serious and be really clear
what the consequences are and update those pause those that training and the
thing I’ve also learned about training that’s important to think about is that
there’s this three a third a third a third rule about any kind of new
technology so the first third of the group of people are going to jump on and
be really excited to use social media and the second group are like yeah yeah
yeah sounds good but they’re not really going to do much until they see that
first group success especially if you’re in financial services the financial
advisor if he or she begins to build a book of business or better book of
business there’s a social media a lot of people
there be interested in that right but they take a few months so whatever
training you develop it needs to be someplace that that second group of
people can get at without going back and admitting they really weren’t paying
attention the first time so it should be on your LMS or to be easily accessible
your internet whatever you use they should be able to go back and look at
the training go through the training to remind themselves ah okay now I’m ready
so have your training for the weather whatever it is have it accessible to
everyone and then also think about training based on roles and position
because people will use social media in a different way and there’s not any one
one you know set of training that’s going to be appropriate so vary that
training and also not everyone learns the same way some people learn online or
webinars and then there’s gonna be people at your bank we’re gonna need
over the shoulder training we’re gonna actually need someone come in and show
them how to use social media effectively and that might be worth it for certain
groups of people yeah I love to I love so much of what you just said there and
if I was like to try to recap it it’s you have to train that if your training
and policies have to evolve there’s never just a set in forget it kinda
mentality because of the evolving nature of these platforms and policies and
marketing people and everything and it also has to be easily and publicly not
publicly but accessible for everyone in your institutions so that they can come
and learn on their own pace or in the method that that works for them I think
those are also so critical as it relates to the person who sets these policies it
can be hard to stamp to date on everything that’s happening like we it
is changing quickly the our new platforms our new best practices and so
I’d say a decent chunk of my time as a social media manager is spent just
reading articles and trying to absorb information and think about it so that I
can effect as we look for these risks and market are there any resources out
there that really you can bring together the compliance the social media world
nicely so people can stay up to date on these or things that you use personally
for me personally I ten conferences I attend the FINRA
annual conference there’s also a FINRA advertising and advertising regulation
conferences coming up in October I happen to learn best in an in-person
setting I also write articles for Forbes on the intersection of regulations and
social media and I find my articles basically on seeing people on Twitter so
I look on Twitter and I will search on to compliance or banking or social media
or something and I’ll see people talking about these topics and I’ll find
articles so it’s really that’s what I do I try to attend events I take people’s
business cards I I connect with them on LinkedIn I go on Twitter and I find out
what’s going on by doing searches and then because I because I also write for
Forbes I actually will interview people and that helps me learn what’s going on
excuse me up-to-date school I think so yeah I think that speak like if you’re
at a conference because I’m everybody’s gonna write but if you’re at a
conference you take somebody’s business card see if you can connect with them
begin to see what your peers are doing ask for their help
this one person I was just interviewing um as a community banker she offered to
share her social media policies with other community banks and together they
created policies so reach out to your peers would see what they’re doing
because I find I work for a technology providers you know I work for Proofpoint
and the first person that everyone always asked when I go on a sales call
with the sales guys is what everybody else is doing and they’re only
interested in investment investment broker dealers that are like the same
size the same city so if they’ll actually say they’ll tell me the name
what’s someone so doing you know and I can’t tell them the specifics but they
they are only interested in what firms there like them are doing and so you
could find that out by just doing research on your own yeah I actually see
the same thing all the time so that’s great advice
I love that what we’re coming up at the top of the hour so I just wanna say
thank you so much for your time this has been really great it’s been fun and
educational if you want to learn more about you or
read any of your articles where should they look well you can follow me on
twitter at bell b b:e l ee white that’s one way I also write for Forbes um
twice a month and so just go on to Forbes calm and look up Joanna Bell B
and you’ll find me there and then they could connect with me on LinkedIn if
they like this reference this with this webinar that’s fine too perfect and I
will try to include links to all those things in the description of this video
so thank you again for your time I hope it was good for you too and I think
everyone who’s kidding into this and hopefully I’ll see you on another
session sometimes there I don’t know thank you

One comment on “Social Media and Compliance for Banks and Credit Unions”

  1. Ashutosh Deshpande says:

    Found a new perspective on social media risk & rewards in the banking sector

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