Presenters:

Michael J. Wallace, Esq. President CLIX MG Inc.

Thomas HardyChief Technology Officer, CLIX MG Inc.

Michael WhitbeckPresident RMUPI

FFIEC: Social Media Compliance Risk Management Guidance

Social Media Statistics 93% of marketers use social media for business Social Media is number 1 activity on the web 45-54 age bracket is fastest growing on FB & Google + YouTube reaches more 18-34 than any cable network 189 Million FB users are mobile only

FFIEC 12/19/13 Interagency Teleconference Definition of Social Media

“A form of interactive online communication in which users can generate and share content through text, images, audio, and/or video” Examples: • Company website (and all loan officer pages)• Micro-blogging sites(Facebook, LinkedIn; Google +, and

Twitter)• Blog sites (Yelp)• Photo and video sites (e.g., Flickr and YouTube

Key Messages/Takeaways

Existing compliance laws/regulations continue to apply to activities conducted through social media as they apply to activities conducted through other channels (CFPB- CMS)

Existing risk areas continue to be relevant – Consider particular ways social media can implicate those risk areas

Financial institutions will be expected to use the guidance in their efforts to adequately address risks raised by activities conducted via social media

Some Regulations

MAP Regulation N (24 months marketing material)TILA/Regulation Z (Advertising of rates, terms)FTC Unfair or Deceptive Acts or Practices HMDA, ECOA – Anti Discrimination (Unique issue

are links and group association. These may create perception and or regulatory problems)

Risks of Social MediaUsing Social Media

Regulatory: As stated above, all apply Increase expenses of compliance: Reg. N 24 month requirement Reputation & Brand dilution: Colors, fonts, tag lines, links and groupsPlagiarism, defamation: Improper use of copy-written materialCurrent CMS/review not optimized for Social Media.

Not using Social Media

Competitive disadvantage, missing increased profitsAlienation of Loan Officers and EmployeesConsumer expectation of on-line presenceIncrease of marketing expenses

Practical Tips for Compliance with FFIEC GuidelinesCompanies must have a written Social Media Policy

Employee Acknowledgment: Proof that it was read and agreed to. Links/Groups: Not violate company anti-discrimination policies Disclosure of SM: Base line Clear and Concise: Indicate what is appropriate, provide guidance Grading: Not required, but suggested.

Companies must show regulators that it is implementing the SMP

Review of Use: Institute schedule to review the SM based upon SMP Prior approval of posts: Recommended Archive: MAP Reg. N (24 months) Feedback to Employees/Training: Encourage compliant use of SM Reporting: Management and regulators

Demonstration www.acuclix.com

Key Feature of AcuClixImplements your SMP and complies with FFIEC/CFPB:

Review of Social Media, simplePre-approval of posts Identifies links and groups for compliance Reports for Employees, Management & RegulatorsArchive for MAP Reg N (24 Months)Library of forms, approved content, policies/procedures

Uses technology to lower your compliance costs

Affordable Monthly Pricing

$ 150.00 up to 10 UsersAdditional Users

$ 4.00 11-50 $ 3.00 51-99

Maximum price: $ 500.00New Year Special; Register 2/3 – 2/28; Unlimited $ 150.00 first 30 daysNo contract periodFull refund within 30 days

www.acuclix.com

Questions?Social Media Policy Template will be emailed to

you. Thank you very much