There are many different (and surprisingly overlooked) sources of social media content your firm could be, and probably is, engaged with. You need to be aware of the compliance, legal and business pitfalls that can damage your business and brand reputation when you don’t adequately preserve and supervise social media. Learn how mortgage lenders can use technology to help dramatically reduce regulatory headaches, while cutting down on the time it takes to review social media content.
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Successful Social Media for Mortgage Lenders: Engage With Your Audience While Maintaining Compliance Obligations
1. Successful social media for mortgage lenders: Engage
with your audience while maintaining compliance
obligations
2. What is Social Media?
• Interactive online communication, in which users can
generate and share content through text, images, audio,
and video.
• Different channels/formats:
• Microblogging sites: Facebook, Twitter, Google Plus,
Instagram
• Customer review websites and bulletin boards: Yelp, Google
Local, Citysearch
• Photo and video sites: YouTube, Flickr
• Forums
• Blogs
• Professional networking sites: LinkedIn
• Virtual worlds: Second Life
• Social games; Farmville
3. Social Media is
Ubiquitous
• As of January 2014, 74% of online adults use social
networking sites*
• Fully 40% of cell phone owners use a social
networking site on their phone, and 28% do so on a
typical day.*
• 33% of Facebook posts are done on mobile devices
according to HubSpot
• Social media has a 100% higher lead to close ratio
than outbound marketing
*Pew Internet Project’s research related to social networking
4. New Guidance for
Mortgage Professionals
According to the Federal Financial Institutions Examination Council:
“A financial institution should have a risk management program that allows it to
identify, measure, monitor, and control the risks related to social media.”
Social media: consumer compliance risk management guidance
Federal Financial Institutions Examination Council (FFIEC)
January 2014
5. • CFBP is clear in its guidance. Now lenders must comply.
You should be able to address questions or complaints in a
timely and appropriate manner.
6. Reputation Risk
Even if you don’t maintain a corporate social media presence, you
still must be vigilant:
• Spoofing, phishing, “fraudsters masquerading as the institution”
• Employee’s communications via social media may be viewed by the
public as reflecting the financial institution’s official policies
• Privacy: members posting personal, sensitive, or confidential
information.
7. Critical Considerations
Oversight and Governance
• How to track and manage
• How to train
• When to say “NO”/Fight sales’ pushback
• Establish a code of conduct
• Train and re-train all employees, especially sales, servicing, marketing
• Have employees self-register their online presences through internal
company records
8. Step 1 – Create a Policy
• Define your social media objectives
• Set policies and procedures regarding the use and monitoring of social media
• Establish an employee training program that incorporates company policies and
procedures for official and unofficial use of social media
• Establish content guidelines
• Define a list of impermissible activities for employees
• Create a written plan that provides controls and ongoing assessment of risk in social
media activities
9. Best Practices: Policy
Creation
• Who’s doing the talking?
• Be listening
• Determine the rules
• Prepare for the worst
• Hold people accountable
• Make it a living document
10. Listening Channels
SET UP YOUR LISTENING CHANNEL
• GOOGLE ALERTS
• NEWSLE
• TWILERT
• LINKEDIN
• MENTION
• TWITTER
11. Step 2 – Monitoring &
Governance
• Design a social media risk management program with participation from various
aspects of the business unit, including legal, sales, marketing, compliance, technology,
information security, and human resources.
• Create a governance structure with clear roles and responsibilities.
• Define oversight process for monitoring information posted to the internet.
• Set audit and compliance functions to ensure ongoing compliance with internal policies
and all applicable laws and regulations (CFPB, State Regs.).
• Establish reporting methodology for information to senior management on social media
risk issues
12. Considerations for
evaluating solutions
Pre-Review vs. Post-Review
Multiple Content Types
Hosted vs. On-Premise
Admissibility of monitored data
Website monitoring
Replication of data
Contextual review (don’t flatten!)
Automated policy review
13. Q&A
Contact Info
Dan Carroll /dcarroll@smarsh.com
www.smarsh.com
facebook.com/SmarshInc
@SmarshInc
Linkedin.com/companies/smarsh
Editor's Notes
But as with everything else in the mortgage industry, there are rules that govern how we behave in these outlets. Innovation usually outpaces regulation, but regulation eventually catches up and holds firms accountable for activities even before the guidance was completely clear. So you must ask yourself, what policies does your firm have in place and what regulations do apply to social media? As a registered representative you need to know what the regulators are saying about electronic communications, including social media, and they are saying a lot.
(same talking points from SEC slide in FiPath deck)
A social media policy documents the guidelines and rules of social media activity performed by you or your advisors as they pertain to the vision and philosophy of your business.
Who is authorized to represent the firm in a social capacity? What is your plan for when your primary social media person leaves the company?
Appoint someone to monitor the outbound activity of the firm and the external online chatter about the company.
Detail every requirement regarding compliance and archiving around social media and clearly specify the consequences of non-compliance.
Despite all the best planning, sometimes things go awry. Include a plan for the worst-case scenario and make sure your policy has every base covered.
Have a system in place to distribute your firm’s social media policy, with specific actions outlined for people who need to sign and return the policy to your HR, legal, or compliance team. Advisors who use social media on behalf of your firm must acknowledge and understand that communications over networks will be archived and supervised, in accordance with compliance regulations.
Regularly review your social media policy to keep up with the needs of your business, changing technology, and new regulations.
SET UP YOUR LISTENING CHANNEL To develop a listening channel, here are some mostly free tools to get you started. Create a separate email address (ex: listen@yourorg. com) to help you sort through all of the email updates you’ll receive.
GOOGLE ALERTS to stay on top of news in your area, specific customers’ activities, and prospect news. Track your firm name and the names of competitors.
NEWSLE is a service that helps you track when your contacts are mentioned in newsletters, articles, white papers, etc.
TWILERT is a Google Alerts version geared for Twitter.
LINKEDIN allows you to search the updates of everyone in your network using specific phrases or words.
MENTION enables users to monitor personal and professional brands, offering a Google-like alert for most every online space.
TWITTER Social profile settings provide a simple way for you to be notified when someone tweets your name or firm name. Check the settings area under mobile and email. Facebook has a similar function.
Monitoring solution should be automated – don’t rely on a manual process that allows for missing or deleted information
Solution should account for multiple message or content types: websites and social media
Solution should capture and render each message type in its original native format
Ensure you’re capturing all content including comments, likes, uploads, etc.