The Federal Financial Institutions Examination Council (FFIEC) released proposed guidance entitled Social Media: Consumer Compliance Risk Management Guidance.
The Guidance addresses the applicability of federal consumer protection and compliance laws, regulations, and policies to activities conducted via social media by credit unions and other regulated financial institutions. The proposed Guidance does not impose new requirements on credit unions. Its purpose is to help financial institutions “understand potential consumer compliance and legal risks, as well as related risks, such as reputation and operation risks associated with the use of social media, along with the expectation for managing those risks.” The Credit Union National Association is working on a Comment Call summarizing the proposed Guidance.
Missouri Credit Union Association (MCUA) Compliance is reviewing the Guidance and will have further comments in the near future. In the meantime, we remind credit unions that, regardless of the Guidance, credit union communication via social media is already covered by existing law and regulations, such as ECOA/FHA/Regulation B, TILA/Regulation Z, EFTA/Regulation E, TIS/Regulation DD, Privacy, FDCPA, just to name some.