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Marketing Compliance Corner: Social Media Revisited

Michael J. Wallace Esq.
Feb 10, 2014

Here are some interesting facts: 93 percent of marketers use social media for business, which means only seven percent of businesses do not use social media. The 45-54 year age bracket is the fastest growing demographic on both Facebook and Google+, and social media is the number one activity on the Web (Belle Beth Cooper, @bellebethcooper, July 16, 2013). Regulation and compliance risk certainly are concerns. However, this should not prevent your company from using this marketing channel. The question is not should you use social media, but rather, how to use it compliantly and manage the risks to reap the rewards of this marketing tool. Companies may not use social media because of the concern that the cost and hassle factor of managing and reviewing it are too onerous. After all, companies have to comply with all of the federal and state rules and regulations concerning marketing. We believe that your company can manage the risk in a cost-effective manner. Here are some practical tips for managing your risk: 1. Create and implement a Social Media Policy which should include: a. Disclosure of all sites used by each LO (including Web sites/pages); b. A detailed review process/procedure for LO with a grading system; c. Feedback to the LO and management; d. Disseminate policy and updates to all staff; 2. Establish and implement review process/procedures: a. Train compliance staff to identify and correct posts b. Provide written reviews to loan officers and management c. Maintain copies of all reviews, posts for Reg. N purposes; d. Implement a system to use or purchase an existing tool to assist with the process; 3. Train, train and train: Educate the LO and all staff about the proper use of social media including: a. Copyright, use of various words, phrases, logos and privacy issues b. Private and business uses (social media, Web sites, e-mail addresses) c. All federal and state rules and regulations that apply generally to marketing and communication are applicable to social media. 4. Develop a library of compliant and relevant posts for LOs to use. This may set your Company ahead of competitors. Please feel free to contact me with any questions or comments: Michael J. Wallace Esq., president of CLIX MG by phone at (727) 474-0961 or e-mail [email protected] Social Media Management System (SMMS) is a Web-based tool to help compliance staff implement the company’s social media policy. SMMS reduces overhead costs and helps review the use of social media, identify and correct compliance issues and complies with Regulation N as well as the Consumer Financial Protection Bureau’s requirement for a CMS. For more information, visit www.clixmg.com. Michael J. Wallace Esq. is president of CLIX MG. Marketing Compliance Manager (MCM) is a Web-based compliance management system for marketing and lead programs, including social media. For a 15-minute live demonstration, please visit www.clixmg.com. He may be reached by phone at (727) 474-0961 or e-mail [email protected]
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