Social Media Policy
Many compliance departments and executives are having a hard time wrapping their arms around developing social media policy. The harm in this thought process is that the CFPB examiners are quite savvy about it.
Did you know that prior to an exam, and many times before an exam letter, you are being “googled” or “binged”? The information that they find helps them uncover issues in advertising (UDAAP) and highlights the way a company monitors this new medium.
I will be the last person to say that you should not use social media. I truly believe it is here to stay and a very viable way to market your services.
Policy development and monitoring will protect your company and get everyone on the same message.
Here are some tips from those who have successfully reigned in their social media presence.
1. Google and Bing your company name and every one of your loan originators, to see what information is on the web representing your company.
2. Manage independent websites for loan originators. This may require you to update your company website so that each loan officer can have their own business page. By doing this, you are able to archive the information being posted and monitor for compliance. Some of the most successful mortgage originators understand this approach and have gladly acquiesced. Why? Well, it is best for the company and for them. Mortgage originators can be fined and held responsible for the content they advertise. So isn’t it much better to have that content reviewed so that no one pays fines?
3. Look for “company” Facebook accounts in the name of your originators. Everyone is entitled to their own personal space in social media, however a company Facebook page, or an originator who has an individual “business” page needs monitoring. This type of monitoring, for most companies, is nearly impossible; so many companies have made the decision that their policy is no individual “business” Facebook pages. Instead, they use one company page which can be easily monitored. There are also companies that can set up your company Facebook page, and each individual originator page. Then, only posts that are pre-approved content can be posted to those pages.
4. Make Decisions:
- Decide what will and will not be acceptable for any type of social media.
- Define what types of “business” profiles an employee can have such as LinkedIn.
- Define types of social media that are not acceptable like “you tube” videos that have not been approved.
- Define appropriate and inappropriate ways of using your company name or logo.
- Give guidance to your staff regarding types of postings that result in penalties.
5. Formulate an approval process for new social media venues and content. For instance, can one of your originators have a “yelp” account? If so, what is acceptable content? It is unlikely that you will be able to keep up with all of the new ways to market unless you have a social media manager, which is why an approval process is important.
6. Archive, Archive and Archive. Anything that is posted needs to be archived. You can automate this process by having postings go directly to a blog page. This works especially well if you have many loan originator pages.
7. Look for “knock off” sites that use your company name or logo. Then take appropriate legal action to remove them.
The worst surprise is an examiner who shows you information from the Internet that you did not know existed! Awkward!!