An Article for the Mortgage Industry on Compliance in Social Media Marketing

1. By Maureen Cioni
For many, social media is a place to
unwind. We use it not only for informa-
tion and to stay in touch with others, but
also for entertainment, whether it be silly
quizzes, cat videos or funny memes.
Social media is largely for relaxing. But
for mortgage professionals, social media
can actually be a bit stressful.
“How can I engage clients and sell my
business on social media with all these
compliance rules and regulations?
Won’t compliance take the fun out of
social media? What can I post or not
post to stay compliant?”
As social media manager for my com-
pany, these are just a few of the ques-
tions I get from loan officers every
month. They’re good questions, too.
When using Facebook, Twitter,
LinkedIn or any other social media
platform, mortgage companies and
loan officers need to walk a fine line
between what is compliant and true
social engagement. In a world where
lending rules are constantly evolving,
and where screen grabs and images can
be cropped to exclude the true context
of what someone posts online, there
are many reasons to be careful.
However, compliance can co-exist
with social media. Here are three rela-
tively simple steps lenders can take to
mitigate the risks while freeing up loan
officers to have fun, engage prospects
and sell loans, whether on Facebook or
any other social platform:
Create a policy
If lenders want to market themselves on
social media, they need to create some
ground rules. We are still in the early
stages of the social media generation,
and most people trying to generate
business on Facebook, LinkedIn and
Twitter are learning through trial and
error. That’s not going to work for mort-
gage professionals, who must abide by
multiple state and federal regulations.
A social media policy, something
written down and shared with the
organization, should cover best prac-
tices as well as what not to do. For
example, Mortgage Network’s social
media policy doesn’t allow loan officers
to post rates on Facebook and other
outlets. Why is that? It may sound far-
fetched, but if you post a rate with dis-
closures, someone could screenshot
that post, crop it and demand the same
rate days later after the rate has
increased. Suddenly, you have a fight on
your hands to prove the rate is wrong.
At the very least, posting rates on
social media can cause confusion and
create situations that result in online
slander or bad reviews. It’s the kind of
thing that makes our industry skittish.
Educate your team
With a buy-in from the sales force,
online engagement and compliance can
walk hand in hand. Creating a social
media policy comes first, but an effec-
tive policy is more than a set of rules. It
should be a training tool to help the less
socially experienced navigate these new
waters with the proper guidance.
For each type of social media activity,
my company’s policy lets our staff know
what information must be disclosed,
such as company e-mail, licensed mail-
ing address, NMLS numbers and the link
to online legal disclosures. It also goes
over the correct use of our licensed busi-
ness names, as well as rules about post-
ing information without consent and
what someone can and cannot post. The
policy also includes proper social media
etiquette, such as dealing with negative
reviews and “trolling,” as well as when
an official response may be needed and
when to take conversations offline.
Our policy was created through a
joint effort by the company’s marketing
and legal departments, and it is a liv-
ing, evolving document accessible to all
employees online. The whole point is to
protect the company and our loan offi-
cers, but also to give our people the free-
dom to use social media and effectively
engage with an audience. For social
media novices, our policy and training
also takes a lot of the guesswork out of
social media platform and how to use
them.
Because of its popularity, we created
a separate policy for Facebook that
applies to all Facebook business pages
used by our loan officers and branches.
It covers what can be posted and what
we do not tolerate on our pages, such as
profanity and threats. It also addresses
third-party links, ownership information
and, of course, Mortgage Network’s cur-
rent and full legal license disclosures.
Track the results
Once you have a social media policy,
how do you enforce it? How closely
should you monitor whether people are
following it? I think these are the hard-
est questions to answer, because every
lender is different. However, making the
policy available online and requiring
anyone involved in social media at your
company to read and sign it is a good
start. This way, no one can claim igno-
rance for violating the policy. If done
electronically, a lender could even have
its staff review and sign the policy every
year.
Training is very key to enforcement.
We hold monthly live webinars where
Mortgage Network employees can come
and ask questions about social media,
get help, discover new sources of content
and hear from colleagues that are having
success on social media. It’s a popular
class, and we all learn something new
each time.
For lenders, social media monitoring
can be done either manually in house or
by enlisting a third party. We keep a
spreadsheet of all employees using
social media, and we track their page
links and spot-check their pages for
usage and compliance. We also have a
private social media Facebook group
enables employees to post questions
and share ideas.
There are quite a few social media
management providers that will even
create content for loan officers and
push it out to them on a daily basis for
posting. Some services even monitor
the use of specific keywords that could
be a sign of policy infringement before
the post goes out. Of course, these
services come at a cost; for smaller
lenders, hiring a social media manager
might be the way to go.
Don’t forget to engage!
Compliance is ever-changing in the
mortgage industry, but mortgage pro-
fessionals can successfully use social
media and stay compliant, as well. It
takes effort and planning, but staying
ahead of what the auditors look for
will benefit everyone in the long run.
However, there is a critical piece to
the social media puzzle that too often
goes missing: engagement. Creating a
social media policy and sharing com-
pliant content are just tools to help
loan officers have online conversations
with people. After all, you can create
all the policies you want, but if loan
officers aren’t actively engaging poten-
tial borrowers online, what’s the point?
In my view, loan officers as a whole
could be much more proactive on
social media. Find people who have
questions about the mortgage process
and help answer them (and don’t just
sell to them!). Become a resource to
those who need help with a specific
type of financing, such as VA or 203k
loans. Join in conversations with oth-
ers, be a real person and have fun.
That’s when you’ll start to see a return
on your investment. After all, compli-
ance can keep you safe on social
media, but only engagement will bring
you success.
Maureen Cioni is social media manager
for Danvers, Mass.-based Mortgage
Network. A marketing and communica-
tions expert with 19 years of experience
in the mortgage industry, Cioni is
responsible for promoting Mortgage
Network through social media, as well
as providing social media training for
loan officers and expanding the compa-
ny’s Web presence. She can be reached
by e-mail at mcioni@mortgagenet-
work.com.
“When using Facebook, Twitter, LinkedIn or any other social
media platform, mortgage companies and loan officers need
to walk a fine line between what is compliant and true social
engagement.”
A Happy Medium: Three Steps to
Staying Compliant on Social Media
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JULY2015■NationalMortgageProfessionalMagazine■NationalMortgageProfessional.com