Social Media: FFIEC Consumer Compliance Risk Management Guidance

This presentation will cover regulatory expectations regarding social media and provide you with the information you need to develop your risk management program. 

Are you in compliance?  On December 11, the FFIEC issued guidance which requires financial institutions to develop a social media risk management program. Even if you aren’t engaged in social media, you are expected to have a program and policy to address employee use. This presentation will cover regulatory expectations and help you develop your program.

The use of social media among financial institutions has been increasing at a rapid pace for the last several years with institutions developing Facebook sites, Tweeting on Twitter, and publishing YouTube videos.  In response to the social media craze, the FFIEC released the Social Media Consumer Compliance Risk Management guidance on December 11, 2013.  The guidance requires institutions to develop a risk management program to address consumer compliance risks as well as operational, legal and reputational risks posed by social media activities. 

The guidance is primarily focused on the institution’s use of social media and understanding the risks associated; however, even if your institution isn’t engaged in social media you are expected to have a risk management program and policy to address employee use.


  • Compliance Risk Management Expectations – Financial Institutions should have a risk management program that allows it to identify, measure, monitor and control risks related to social media.
  • Risk Areas – The use of social media to attract and interact with customers can impact a financial institution’s risk profile, including risk of harm to consumers, compliance and legal risks, operational risks, and reputation risks.
  • Employee Use of Social Media Sites – Employee use can also subject the institution to compliance and reputation risks.
  • And More…


Senior management, IT officers, compliance officers, risk management officers, internal auditors, marketing and HR.


Susan Orr, CISA, CISM, CRP, CRISC, is an industry expert with vast regulatory, risk management, and security knowledge. During her 14 years as bank examiner, Susan held numerous lead positions including Regional IT Examination Specialist, Special Assistant to the Regional Director, and Special Assistant to the Vice Chairman of the FDIC. Susan was lead instructor for the FDIC’s technology school. She currently consults for security providers and performs IT security/regulatory reviews for financial institutions.

Credit Information

Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2 hours/session CRCM/CLBB 


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